United States of America and Howard W. George, Special Agent, Internal Revenue Service v. Donald E. Cote

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• stating that the accountant’s “prior employment ... is not controlling” in determining whether the attorney-client privilege applies to an accountant’s communications
• noting that the attorney-client privilege does not “attach to information which the taxpayer intends his attorney to report in the contents of a tax return”
• disclosure, on amended returns, waives privilege with respect to data on returns as well as underlying data
• attorney-client privilege attaching to information contained in accountant's workpapers waived by publishing the substance of that information in amended tax returns
• accountant’s papers used by attorney to advise client privileged because decision to file amended tax return “undoubtedly involved legal considerations”
• privilege can extend to an expert consultant such as an accountant or a foreign language interpreter retained by an attorney to assist him or her in understanding information on which the attorney has been asked to render legal advice

Source: CourtListener parenthetical corpus (CC0).