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Bibframe Work

Title
The section 7525 tax practitioner-taxpayer privilege and related issues
Type
http://id.loc.gov/ontologies/bflc/Deprecated
Text
Integrating
Language
English
Geographic Coverage
Notation
Script: Latin
Content
text
Summary
"... discusses section 7525 of the Internal Revenue Code, a statutory privilege applicable to communications between federally-authorized tax practitioners and taxpayers relating to tax advice. A federally-authorized tax practitioner is anyone who is authorized to practice before the I.R.S., including attorneys, CPAs, enrolled agents, enrolled actuaries, and others. With certain important exceptions, the section 7525 privilege is co-extensive with the attorney-client privilege and thus incorporates a rather extensive body of law that has developed in the federal courts. The portfolio discusses in detail the statute, its purpose and legislative history, the attorney-client privilege, and judicial and administrative guidance on the meaning and application of section 7525. The portfolio also covers related issues including state-created accountant privileges and the work product doctrine, both of which may be available to protect communications and documents made or created by non-attorney tax practitioners. "
Table Of Contents
Detailed analysis. Introduction
The section 7525 privilege
Limitations on the section 7525 privilege
The Kovel doctrine: privilege when accountants and other non-attorneys assist attorneys
State law issues
Work product doctrine
Table of worksheets.
Serial Publication Type
loose leaf
Authorized Access Point
Boylan, Kim Marie The section 7525 tax practitioner-taxpayer privilege and related issues