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The Attorney-Client and Work Product Privileges in the Tax Context

In Attorney-Client Privilege, Privilege, Tax Litigation, Work Product Privilege by Jason Freeman and Katie ManworrenLeave a Comment

A recent case reveals the perils of maintaining the attorney-client and work product privileges. As it demonstrates, additional precautions may be necessary in the context of privileged documents that are utilized in the tax context, particularly where those documents are used to support a reporting position.   United States v. Sanmina Corporation & Subsidiariesinvolved a dispute between the IRS and …