More Facts Resolve Tax Risks –

Legal Privilege –

ANY OPINIONS OBTAINED from the outset, before and pursuant to an IRS query, must be protected by legal privilege . This will ensure they do not have to be disclosed to the IRS at all, even if the matter eventually goes to court.

Opinions may contain qualifications or provisos. For example, counsel may arrive at a finding on the assumption of something. If this gets into the IRS’s hands, they could focus on that qualification and misinterpret it entirely.

Taxpayers must make sure to furnish counsel with every last detail in order to avoid such assumptions.

In accordance with Circular 230 Disclosure