Tax Notes Quotes Chris Rizek on Tax Practitioner Privilege

Tax Notes Today

Tax Notes captured Christopher S. Rizek's panel discussion "Ch-ch-ch-ch-changes, Turn and Face the Strange Times in Regulating Tax Practitioners," which focused on developments in the regulation of tax practice and tax ethics. For the complete article, please visit Tax Notes's website (subscription required).

Excerpt taken from the article "Expanding Ridgely Would Contract Tax Return Preparer Privilege" by Nathan Richman for Tax Notes.

The tax practitioner privilege under section 7525 is defined by reference to the same statute on which Circular 230 is based -- 31 U.S.C. section 330 -- Christopher S. Rizek of Caplin & Drysdale Chtd. noted November 20 at the Parker C. Fielder Oil and Gas Tax Conference in Houston. "One of the unanticipated consequences, I think, of attacking who is a practitioner under [31 U.S.C. section] 330 may be it undercuts further [section] 7525, which is already full of holes," he said.

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Work Product

Rizek disagreed, saying, "This fight isn't over the factual portion of those memos." Rather, it is about the IRS seeking a roadmap of the transaction's analysis, warts and all, he said, adding that if the issue had been only the facts, Schaeffler would not have made it to the Second Circuit.

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