Posts tagged "attorney client privilege"

Taxpayers can waive the attorney-client privilege by raising good faith and state-of-mind defenses during litigation

The Tax Court recently issued an opinion in AD Investment v. Commissioner, 142 T.C. No. 13, in which the Court granted the IRS's motion to compel the production of documents. The controversy arose in the context of two consolidated Tax Court proceedings involving partnership-level actions related to a possible Son-of-BOSS tax shelter from tax year 2000.

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