These opinion letters effectively state that, based on the information available to the law firm, the transaction in question appears legal and proper.

These lawyers charge up to a million dollars for an opinion letter, which the lawyer can repeatedly resell.

The firm charged an average of $74,000 an opinion letter, and in one instance $900,000.

The opinion letter is required to contain a paragraph that defines the authorized user of the report.

On Nov. 14, 2000, a conflicting opinion letter was issued by the office of the attorney general.

It also contains a selection of opinion letters he wrote regarding contemporary issues in the Jewish world.

The real value of opinion letters is as a shield from government penalties for not paying taxes when they were due.

Ernst & Young even gave clients a pricing sheet on what the opinion letters would cost.

"I signed opinion letters knowing them to be false."

Investors use the opinion letters as reassurance that the shelters are valid.