(1) Tax Court cases are NOT responsive here because an important purpose of RA 5 is to make sure that you are or become familiar with the other federal courts that handle taxpayer vs. IRS litigation. It is okay if it’s a federal appeals court and the case had started out in Tax Court (thus “Commissioner” rather than “United States” in the caption). Just not a T.C. or T.C. Memo case as your only source.
(2) Be sure that the 7525 issue is centered on tax advice from a CPA or accounting firm. Nothing originating with a law firm. Nothing resembling financial statement audit workpapers or anything else other than tax advice, which typically in these cases will be taking the form of a written tax opinion that the IRS is trying to get its hands on through the pretrial discovery process.
It would be unusual — not unheard of, but unusual — for a 7525 case to involve only single document — a tax opinion and nothing else at all. Most 7525 cases involve multiple documents that the IRS is trying to get its hands on. It doesn’t matter what the court decides as to any other documents. The only thing that matters in this assignment is the Court’s 7525-based decision as to tax advice that had been communicated to a client by a CPA or accounting firm. That’s what matters. What happens as to any other documents irrelevant.
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