US Tax Court Frustrates IRS Attempt to Expand Privilege Waiver



Robin Greenhouse, Roger Jones, Andrew Roberson, Kevin Spencer and Jeffrey Glassman wrote this bylined article on Estate of Levine v. Commissioner, in which the US Tax Court rejected an Internal Revenue Service attempt to expand upon existing privilege waiver principles. “Taxpayers should carefully scrutinize IRS attempts to obtain privileged documents, and resist the IRS’s attempts to expand the waiver concept beyond reason and principle,” the authors urged.