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IRS LOSES ANOTHER ACCRUAL WORKPAPER CASE
May 13, 2008
The IRS has lost its second district court case seeking workpapers used in developing the tax accrual for a public company's financial statements.
According to Tax Analysts ($link), this decision involved 20 documents totaling 151 pages; another 260,000 pages were turned over to the IRS. Tax Analysts reports:
The court conducted an in camera review of the withheld documents. The documents all related to one transaction engaged in by Regions.The core documents -- documents created by E&Y and the law firm Alston & Bird LLP -- expressed opinions, provided legal theories, and listed possible attacks by the IRS. The other documents at issue, called derivative documents, explained, discussed, or quoted the core documents.
This decision, even if upheld, doesn't seem like an enormous taxpayer victory, as it applies to a narrow set subset of the audit workpapers.
Link: Court order and copy of summons
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Comments
Isn't this just an affirmation of attorney-client privilege?
Posted by: chris | May 13, 2008 10:10 AM