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    #16
    Originally posted by Gary2 View Post
    To be precise, it only means that the prohibition against disclosure under section 7216 does not apply. That doesn't mean there are no other obligations against disclosure.

    In particular, section 7525 specifies that limited common law protections of confidentiality apply to such communications. While many of us are familiar with the limits of this privilege, I've never seen a legal discussion of our obligations under this section.
    Does 7525 include communications with the IRS?
    Believe nothing you have not personally researched and verified.

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      #17
      Originally posted by taxea View Post
      Does 7525 include communications with the IRS?
      It explicitly says that the privilege may only be asserted in non-criminal matters before the IRS and in non-criminal matters in Federal court in proceedings by or against the US, so yes, it clearly applies to some communications with the IRS.

      As luck would have it, someone at the Quatloos forum posted a pop-quiz on the interaction of privilege with bankruptcy proceedings and state law. A number of the participants in that forum are attorneys, though I haven't kept track of which ones are. But the mere fact that the quiz includes answers such as "Has violated Texas law, relating to regulation of CPAs, but has not violated the Internal Revenue Code" suggests that the issues may be complex, and shouldn't be ignored.

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