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transaction, including financial risks, tax risks,
audit risks;
(e) all other documents relating directly or
indirectly to the tax and/or financial
consequences of participating in the transaction.
2. Provide all legal, tax, accounting, financial
or economic opinions secured or received in connection
with the transaction.
Petitioner objects, principally on the grounds of privilege,
but has provided to both respondent and the Court a privilege log
and a revised privilege log. The revised privilege log lists 20
documents, all of which were (1) either addressed to, received
from, or copied to an attorney or C.P.A., (2) described as
“advice regarding tax law,” and (3) withheld from respondent on
the basis of a claimed privilege described, in each case, as
“attorney-client; Work Product; §7525.”3 In his response to
petitioner’s objection to the motion to compel production,
respondent does not dispute petitioner’s description of the
documents as “advice regarding tax law”. Rather, he alleges that
petitioner failed to sustain its claim that those documents are
privileged, and he requests that we “order the documents produced
or [,] alternatively, inspect the documents ‘in camera’ to
determine whether the asserted privilege or protection applies.”
The Court has not ruled upon the motion to compel
production.
3 Sec. 7525(a)(1) provides a limited privilege, equivalent
to the attorney-client privilege, to communications regarding tax
advice between a taxpayer and “any federally authorized tax
practitioner”.
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Last modified: March 27, 2008