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Article: Recent court decision demands increased diligence when discussing privileged information.(United States v. KPMG, 2002 U.S. Dist. LEXIS 24830 (D.DC 2002))
- Article from:
- The National Public Accountant
- Article date:
- June 1, 2003
- Author:
CopyrightCOPYRIGHT 2003 National Society of Public Accountants. This material is published under license from the publisher through the Gale Group, Farmington Hills, Michigan. All inquiries regarding rights should be directed to the Gale Group. (Hide copyright information)
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Individuals and companies involved in sophisticated tax planning constantly communicate with their outside tax advisors (both attorneys and accountants). A recent federal court decision made clear the distinction between attorney-client privilege and accountant-client privilege in terms of safeguarding the privacy of communication in sensitive tax matters.
In United States v. KPMG, 2002 U.S. Dist. LEXIS 24830 (D.DC 2002), the court sought to determine the ability of the IRS to seek disclosure of various documents. In holding that information prepared for the purposes of a tax return is not privileged under either section 7525 of the IRS Code (granting statutory ...