IRS Summons Reaches Attorney’s Client Names

Houston Tax Attorney

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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 […]

IRS Agents Contact Third Parties During IRS Audit

Houston Tax Attorney

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We often get questions as to whether IRS agents can contact various third parties during the course of an IRS audit. The general rule is that IRS agents can in fact contact third parties. And they sometimes do. The ability to do this is limited and it does not exempt IRS agents from the confidentiality […]

The IRS’s Reach in a Research Tax Credit Audit

Houston Tax Attorney

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The IRS has a track record of taking aggressive stances when auditing research tax credits.  But its position in the Bayer Corp. & Subs v. United States, Civil Action Nos. 08-693, 09-351 (W.D. PA 2010), raises the question whether a taxpayer claiming a research tax credit is signing up to disclose their confidential information.   Facts & […]

IRS Disclosure of Confidential Information

Houston Tax Attorney

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The IRS is prohibited from disclosing taxpayer information to third parties.  There are a number of exceptions.  But when the laws are violated, the courts can and do award damages to taxpayers.  The Ward v. United States, 973 F. Supp. 996 (Dist. Colo. 1997) court case provides a prime example. Facts & Procedural History The taxpayer owned […]