Tag Archives: U.S. v. Adelman

ATTORNEY-CLIENT AND TAX PRACTITIONER PRIVILEGES

Posted on March 26, 2010 by David L. Silverman, J.D., LL.M. (Taxation)

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 →

Posted in Attorney-Client Privilege | Tagged "legal advice", 134 F.3d 1194 (1998), 465 U.S. 805 (1984), attorney work product, attorney-client privilege, IRC § 7525, privileged communication, U.S. v. Adelman, U.S. v. Arthur Young and Co., work product doctrine | Leave a comment

Attorney-Client Privilege in Tax Disputes

Posted on March 25, 2010 by David L. Silverman, J.D., LL.M. (Taxation)

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 →

Posted in Attorney-Client Privilege | Tagged anticipation of litigation, attorney-client privilege, Cavallaro v. U.S., confidential communications, disclosures to accountants, IRC § 7491, IRC § 7525, privileged communications, tax disputes, U.S. v. Adelman, U.S. v. Frederick | Leave a comment

Tag Archives: U.S. v. Adelman

ATTORNEY-CLIENT AND TAX PRACTITIONER PRIVILEGES

Attorney-Client Privilege in Tax Disputes

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