Taxpayers Must Reveal Tax Shelter Opinion Letters Despite Attorney-Client Privilege

By attempting to establish good-faith and state-of-mind defenses,
taxpayers put their legal knowledge and understanding into contention,
and therefore they waived attorney-client privilege.

Source: http://feedproxy.google.com/~r/AICPA_Tax/~3/g1w382HzwxE/20140416.aspx

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