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Tax Litigation Tax Procedure

IRS Summons Reaches Attorney’s Client Names

Communications with an attorney are generally protected from disclosure.  But what about client names?  And what power does the IRS have the power to force an attorney to disclose the names of his clients?  The court addressed this in U.S. v. Servin, No. 17-1371 (3d Cir. 2018). Facts and Procedural History The case involved an attorney […]

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IRS Penalties Reasonable Cause Tax Procedure

Reasonable Cause Defense for Penalty Waives Privilege

In Eaton Corporation & Subsidiaries v. Commissioner, the U.S. Tax Court concluded that raising the reasonable cause/good faith defense to tax penalties waived the work product, attorney-client, and federal tax practitioner privileges. This is a serious issue that has to be considered when submitting penalty abatement requests based on a reasonable cause defense. APA (Advance […]