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Evidence Keyed to Park
Evergreen Trading, LLC v. United States
Citation:
80 Fed.Cl. 122 (2007)Facts
Plaintiff challenged a determination by the Internal Revenue Service that they were subject to penalties for underpayment of tax because their returns improperly reported the treatment of a series of transactions. Prior to 1998, the Supreme Court repeatedly held that no confidential accountant-client privilege exists under federal law. In 1998, however, Congress enacted section 7525 of the Code that provides: with respect to tax advice, the same common law protections of confidentiality which apply to a communication between a taxpayer and an attorney shall also apply to a communication between a taxpayer and any federally authorized tax practitioner.
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