3. Alices coffee shop is audited again. This time, the IRS reviews the Schedule C reporting income and expenses for the sole proprietorship that is included on the joint income tax return filed by Alice and Brian. Exam determines that Alice and Brian underreported their income taxes in 2015 by $20,000.

a. Brian wants your advice on whether the IRS can collect the liability from him, since it stems from Alices coffee shop. He claims to know nothing about how the coffee shop works. What options does he have if he does not want to pay this debt?

b. What are your Circular 230 obligations in giving this advice to Brian if you also represent Alice before the IRS?