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
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.
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