This overview provides a discussion of the various confidentiality privileges that shield taxpayer communications with their non-attorney tax professional from discovery by the Federal government in tax controversy matters.
Taxpayers are entitled to assert confidentiality privilege under Internal Revenue Code Section 7525 similar to the common law attorney-client privilege with respect communications with CPAs and Enrolled Agents.
Also, some taxpayer communications with any expert, including CPAs and Enrolled Agents, enjoy privilege protection from discovery by the government under the "work product" doctrine. Also, communications between clients, attorneys, CPAs and Enrolled Agents may enjoy privilege protection under the "Kovel" judicial doctrine when the professional is retained to assist an attorney.
The significant limitations attached to those non-attorney privileges are critical for those tax professionals to understand and to avoid compromising a taxpayer communicating with an expectation of privilege that will not withstand challenge. The course offers the perspective of the non-attorney tax professional with experience in addressing each of the privilege issues in tax practice.
PICPA Member: $79
Nonmember: $104
Course No. 4193491B
Level: Advanced
Prerequisites: Tax practitioners with two-years experience and a working knowledge of the AICPA Statements on Standards for Tax Services and IRS Circular 230.