Tax Practitioner Client Confidentiality and Privilege Practice Guide
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Tax Practitioner Client Confidentiality and Privilege Practice Guide

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Confidentiality privileges relating to taxpayer communications for federally authorized practitioners was created in 1998 with the enactment of the Internal Revenue Restructuring and Reform Act of 1998 (IRSRRA). In passing what became Sec. 7525, Congress believed that communications between a taxpayer and his or her advisor should be privileged in noncriminal proceedings before the IRS and in noncriminal proceedings in federal courts where the IRS is a party, provided the practitioner is authorized to practice before the IRS.

This privilege

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