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June 2015 » The Kovel Privilege: How Does It...
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Sharon L. McCarthy, JD
A client's communications with an accountant enjoy a limited privilege under the Tax Code. In non0criminal tax matters, that privilege applies to any communication that “would be considered a privileged communication if it were between a taxpayer and an attorney” [IRC section 7525(a)(1)]. In the criminal context, however, no such privilege applies to communications between an accountant and a client, except when the accountant assists an attorney in providing legal advice to a client. This has been well-established law since 1961, when the Second Circuit Court of Appeals decided United States v. Kovel [296 F.2d 918 (2d Cir. 1961)].
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