Solving The Privilege-Penalty Predicament: Part 2

By Brian Kittle, Erin Gladney and Geoff Collins (June 27, 2017, 11:51 AM EDT) -- In 2014, in AD Investment, the U.S. Tax Court held that by asserting penalty defenses, two partnerships waived the attorney-client privilege. In the first part of this article, we examined the consequences of this ruling, and their effect on tax compliance and fairness in tax litigation....

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