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Article: Protecting against the disclosure of trade secrets to independent experts and third-party fact witnesses during an Internal Revenue Service audit.
- Article from:
- Tax Executive
- Article date:
- March 1, 1990
- Author:
CopyrightCOPYRIGHT 1990 Tax Executives Institute, Inc. 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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Protecting Against the Disclosure of Trade Secrets to Independent Experts and Third-Party Fact Witnesses During an Internal Revenue Service Audit
I. Introduction
During a coordinated examination of a large corporation, the Internal Revenue Service typically deploys a team of revenue agents, international examiners, engineers, or economists, who possess broad statutory authority to collect facts regarding the taxpayer's property and business. (1) This authority generally is exercised informally through the agents' issuance of Information Document Requests (IDRs). (2). If the taxpayer fails to provide the requested information on an informal basis, ...