Solving The Privilege-Penalty Predicament: Part 1

By Brian Kittle, Erin Gladney and Geoff Collins (June 26, 2017, 2:55 PM EDT) -- In 2014, in AD Investment,[1] the U.S. Tax Court held that by asserting penalty defenses, two partnerships waived the attorney-client privilege. Our purpose here is to examine the consequences and their effect on tax compliance and fairness in tax litigation.[2]...

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