Article by Ruth N. Holzman, James P. Kleier, Catherine R. Nguyen and Phillip Pillar
Originally published in Reed Smith’s Commercial Restructuring & Bankruptcy Alert, December 2006
A series of recent events affecting tax advice, tax accounting rules and tax accrual workpapers1* underscores the conflict between the protections afforded tax advice under the attorney-client privilege and the work-product doctrine, and the ever-increasing scrutiny of tax reserves by the public and tax authorities:
- In a setback for the IRS, on Aug. 10, 2006, the Court of Appeals for the Sixth Circuit reversed the lower court and quashed a summons of two tax opinions in U.S. v. Roxworthy2, holding that the opinions were protected under the work-product doctrine.
- On Aug....
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