IRC Sec. 7525 Attorney-Client Privilege

IRC Sec. 7525, re: taxpayer attorney-client privilege states:

7525(a)(1) General Rule: With respect to tax advice, the same common law protections of confidentiality which apply to a communication between a taxpayer and an attorney shall apply to a communication between a taxpayer and any federally authorized tax practitioner to the extent, the communication would be considered a privileged communication if it were between a taxpayer and an attorney;

7525 (a)(2) Limitations: Paragraph #1 may only be asserted in (A) any non-criminal tax matter before the IRS; (B) any non-criminal tax proceeding in federal court brought by or against the US.

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