Law360, New York ( June 6, 2014, 10:31 AM EDT) -- On April 16, 2014, in AD Investment 2000 Fund LLC v. Commissioner, 142 T.C. No. 13, the U.S. Tax Court held that, by putting into issue their own legal knowledge, understanding and beliefs with respect to a particular tax position in order to establish their defenses to accuracy-related penalties, taxpayers forfeited the attorney-client privilege with respect to certain communications relevant to the content and formation of such legal knowledge, understanding and beliefs....
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