Attorney Work Product at Risk

A new federal appeals court decision promises to give significant pause to corporate counsel, particularly in-house tax attorneys. To their dismay, the First Circuit has ruled that no amount of anticipation of litigation, nor the intimate involvement of legal counsel, can ever immunize so-called "tax accrual workpapers" from discovery by the IRS.

16 minute read October 26, 2009 at 10:04 AM
By
Anthony M. Sabino
Attorney Work Product at Risk

A new federal appeals court decision promises to give significant pause to corporate counsel, particularly in-house tax attorneys.

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