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KS online Form 8300: What You Should Know

Comment: It appears that the “lawyer client privilege” under Sec. 202 (A) of Title 18 does not apply to this transaction. Thus, Section 202(a) of Title 18 has no application. Similarly, section 202 (i) (1) applies to an attorney and client  Comment to the Tax Protester by MP Harrington · 1995 · Cited by 22 — The purpose of the IRS Rule was to impose a civil penalty on the IRS for willfully filing a false or misleading report. A failure to file is only a crime when  Comment: This rule, while designed to impose a civil penalty, does not have direct application to an officer of the IRS. Even though the rule, if valid, had subjected the taxpayer, such as the IRS, a criminal penalty  Comment to IRS Publication By Michael Schofield · June 24, 2024 · Cited by 12 — If there is no attorney-client privilege as to a communications or report, then disclosure would be a violation of the attorney-client privilege, and also violate the Privacy Act. The federal crime would therefore be an abuse of office punishable as a misdemeanor and subject to up to a year in a jail term. However, if the Rule is used as a basis to determine the privilege of attorney-client communications, the privilege would be violated, and the privilege would be violated no matter who the communicating is. Tax Tip: Taxpayers who seek a violation of attorney-client privilege should not bring a case in the IRS Office of Claims Review or with an attorney, as the court will likely rule that the attorney-client privilege may not be violated. By Michael Schofield · March 15, 2024 · Cited by 11 — A taxpayer who wants to enforce the privilege in a private contract with an individual may contact the attorney for assistance. If the attorney is unable to act to protect the privilege in the private contract, the taxpayer should attempt to negotiate a contract that provides that the attorney-client privilege will not be violated and a copy of this agreement, if a copy exists, will be provided to the IRS. If the contract is not effective, however, then the taxpayer should seek an order from a federal district court finding that the client was in fact an attorney and that the privilege is not violated or a declaration that the privilege was waived by the client by failing to maintain the agreement and provide the requested materials.

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