Privileges - Accountant-Client

United States v. BDO Seidman, 337 F.3d 802 (7th Cir. 2003)

The IRS issued a summons to the large accounting firm, asking for documents that would reveal the identity of every client who sought advice regarding, and ultimately invested in, certain tax shelters. The clients invoked the privilege of confidential communications between an accountant and his client. See 26 U.S.C. § 7525. Because the information being sought did not include actual communications, the summons was permissible. This decision reviews in depth the law surrounding the issuance of IRS summonses and the law of privilege in the context of IRS inquiries.