-
Articles & Seminar Materials
- June 5 NYS Tax Litigation Seminar: Completion Certificate June 2, 2025
- June 5 NYS Tax Litigation Seminar — Outline May 31, 2025
- June 5 Tax Litigation Seminar — Supplementary Materials May 14, 2025
- June 5 CPE Seminar: NYS Tax Litigation — Practice & Procedure April 28, 2025
- March 13 CPE Seminar: Supplementary Materials March 4, 2025
- Income Taxation of New York Trusts & 2025 Planning Strategies March 4, 2025
- Webinar Recording of 1031 Final Regulations Seminar January 16, 2025
-
Natural Language Search
Search by Category
Most Popular
- Welcome
- Qualified Personal Residence Trusts (QPRTs)
- Executor and Trustee Commissions Under NY EPTL
- Executors and Trustee Commissions
- Legal Basis for Seeking Abatement of New York State Tax Penalties
- CV
- Executor and Trustee Commissions Under the New York EPTL
- House Passes $56 Billion “Tax Extenders” Bill
- Letters Testamentary
- Article 78 Appeals to Appellate Division, Third Department
Tag Archives: IRC § 7525
ATTORNEY-CLIENT AND TAX PRACTITIONER PRIVILEGES
The attorney-client privilege protects the confidentiality of communications arising from the attorney-client relationship. Although there is no traditional “accountant-client” privilege, certain communications made by the client to an accountant hired by an attorney to assist in providing legal services may be privileged. U.S. v. Kovel, 296 F.2d 918 (1961). Continue reading
Attorney-Client Privilege in Tax Disputes
The attorney-client privilege protects confidential communications between attorneys and clients. The privilege extends to an accountant hired by an attorney to assist in understanding the client’s financial information. U.S. v. Adelman, 68 F.3d 1495 (2nd Cir. 1995). Privileged attorney-client communications include expressions conveyed through conversations, documents, records and internal memoranda. Even billing and travel records, and expense reports, may be protected if they relate to a privileged matter. Continue reading
