Tax
Jan. 23, 2013
Subpoena for tax documents enforced despite protections
Tax lawyers long have been able to import attorney-client privilege to accountant communications by using a Kovel letter; recent IRS lawsuits, however, are eroding the ability to do so.
Robert W. Wood
Managing Partner
Wood LLP
333 Sacramento St
San Francisco , California 94111-3601
Phone: (415) 834-0113
Fax: (415) 789-4540
Email: wood@WoodLLP.com
Univ of Chicago Law School
Wood is a tax lawyer at Wood LLP, and often advises lawyers and litigants about tax issues.
In taxes, there's a difference between lawyers and accountants. Because of attorney-client privilege, the Internal Revenue Service generally cannot make your lawyer testify or produce documents. Attorney-client privilege is strong. That way clients (in both civil and criminal cases) will be forthcoming with their lawyers.
Accountants, however, don't have this privilege. If you make statements or provide documents to your accou...
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