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Unformatted text preview: the IRS might consider to be a potential fraud case. (B) Answer: No privilege. The accountant privilege is limited to noncriminal tax matters before the IRS or noncriminal tax proceedings in Federal court. 2. Answer: No. The client waived the privilege by distributing the document to a third party. 3. Answer: Yes under both assuming that the clients anticipation of litigation is reasonable. If the IRS subsequently summons the advice memorandum, it would be difficult for the IRS to convincingly argue that there was little prospect of litigation as of the date the advice was given. 4. Answer: This question is intended to encourage class participation and point out that the exceptions to accountant privilege are many and broad, including criminal matters, simple return preparation, and business as opposed to tax advice....
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- Spring '10