Add to ORKGThe struggle between the Internal Revenue Service (IRS) and business taxpayers regarding the discovery of tax accrual work papers is not a new battle. The IRS, seeking a road map of the corporation’s vulnerable tax positions, argues that tax accrual work papers are prepared for ordinary business purposes and are not subject to the protection of the work product privilege as established in Hickman v. Taylor and codified in Federal Rule of Civil Procedure 26(b)(3). Corporate taxpayers, desperate to keep the IRS from discovering work papers containing the probability of success analysis of vulnerable tax positions (not to mention potential tolerance for settlement), argue that tax accrual work papers are prepared in anticipation of potential l...
Congress blundered badly by defining the Federally Authorized Tax Practitioner privilege by cross-re...
Pursuant to its tax-collecting duty, the Internal Revenue Service (IRS) has the power to issue summo...
The Supreme Court of the United States, in a unanimous decision, has held that the control group tes...
The struggle between the Internal Revenue Service (IRS) and business taxpayers regarding the discove...
In its rehearing of Textron, the First Circuit has an opportunity to rectify an error and curb unwis...
When examining a corporate taxpayer, the IRS often seeks special accounting documents called tax acc...
On August 13, 2009, the First Circuit in United States v. Textron Inc. held that tax accrual workpap...
United States of America v. Arthur Young & Company and Amerada Hess Corporation (Docket No. 82-687) ...
The broad summoning power of the Internal Revenue Service [IRS] which enables it to examine any docu...
Although the work-product doctrine has received considerable attention before the courts in recent y...
The Internal Revenue Service (IRS) announced in January 2010 a new initiative to require certain bus...
Given the extremely limited source of resources available to the IRS in recent years, it\u27s not su...
Full and frank disclosure between corporate issuers and their auditors and accounting advisors is cr...
This Note argues that creating a tax-crime exception to the privilege against self-incrimination cou...
Internal Revenue Service (IRS) publications are everywhere in tax practice and almost nowhere in tax...
Congress blundered badly by defining the Federally Authorized Tax Practitioner privilege by cross-re...
Pursuant to its tax-collecting duty, the Internal Revenue Service (IRS) has the power to issue summo...
The Supreme Court of the United States, in a unanimous decision, has held that the control group tes...
The struggle between the Internal Revenue Service (IRS) and business taxpayers regarding the discove...
In its rehearing of Textron, the First Circuit has an opportunity to rectify an error and curb unwis...
When examining a corporate taxpayer, the IRS often seeks special accounting documents called tax acc...
On August 13, 2009, the First Circuit in United States v. Textron Inc. held that tax accrual workpap...
United States of America v. Arthur Young & Company and Amerada Hess Corporation (Docket No. 82-687) ...
The broad summoning power of the Internal Revenue Service [IRS] which enables it to examine any docu...
Although the work-product doctrine has received considerable attention before the courts in recent y...
The Internal Revenue Service (IRS) announced in January 2010 a new initiative to require certain bus...
Given the extremely limited source of resources available to the IRS in recent years, it\u27s not su...
Full and frank disclosure between corporate issuers and their auditors and accounting advisors is cr...
This Note argues that creating a tax-crime exception to the privilege against self-incrimination cou...
Internal Revenue Service (IRS) publications are everywhere in tax practice and almost nowhere in tax...
Congress blundered badly by defining the Federally Authorized Tax Practitioner privilege by cross-re...
Pursuant to its tax-collecting duty, the Internal Revenue Service (IRS) has the power to issue summo...
The Supreme Court of the United States, in a unanimous decision, has held that the control group tes...