This
digital document is an
article from The Tax Adviser,
published by
American Institute of CPA's on June 1, 1996. The length of the
article is 652 words. The page length shown above is based on a
typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.
From the supplier: On remand from the US Court of Appeals for the Second Circuit, the US District Court for the Southern District of New York found that the work-product doctrine did not apply to tax planning memoranda prepared in anticipation of corporate reorganization. The work-product doctrine only applies to materials developed in anticipation of litigation. The Second Circuit had earlier found that the attorney-client privilege did not bar IRS access to these memoranda because there was no contemporaneous documentation distinguishing the services performed by the corporation's accountants.
Citation DetailsTitle: Adlman court holds work-product doctrine is inapplicable to pretransaction memoranda.
Author: Ron, Jr. Buch
Publication:The Tax Adviser (Magazine/Journal)
Date: June 1, 1996
Publisher: American Institute of CPA's
Volume: 27
Issue: n6
Page: 357(2)
Distributed by Thomson Gale.
Price:
$5.95
[
Notify me when price goes down.]