With respect to tax advice, the same common law protections of confidentiality which apply to a communication between a taxpayer and an attorney also applies 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.
A “tax practitioner” shall not reveal information relating to the representation of a client unless the client gives informed consent, the disclosure is impliedly authorized in order to carry out the representation.
A “tax practioner” may reveal information relating to the representation of a client to the extent the “tax practitioner” reasonably believes necessary:
– to prevent reasonably certain death or substantial bodily harm
– to reveal the client’s intention to commit a crime and the information necessary to prevent the crime
– to prevent the client from committing a fraud that is reasonably certain to result in substantial injury to the financial interests or property of another and in furtherance of which the client has used or is using the “tax practitioner’s” services
– to prevent, mitigate or rectify substantial injury to the financial interests or property of another that is reasonably certain to result or has resulted from the client’s commission of a crime or fraud in furtherance of which the client has used the lawyer’s services;
– to secure legal advice about the “tax practitioner’s” compliance with these Rules, other law or a court order;
– to establish a claim or defense on behalf of the “tax practitioner” in a controversy between the “tax practitioner” and the client, to establish a defense to a criminal charge or civil claim against the lawyer based upon conduct in which the client was involved, or to respond to allegations in any proceeding concerning the lawyer’s representation of the client
– to comply with other law or a court order
I am not an employee of the United States Treasury Department or the Internal Revenue Service. I work for and represent tax payers disputing federal and state tax matters.
As a Federally Authorized Tax Practitioner enrolled with the United States Department of Treasury to practice before the Internal Revenue Service, pursuant to the rules of professional conduct set forth in United States Treasury Department Circular 230, nothing contained in this communication was intended or written to be used by any taxpayer for the purpose of avoiding penalties that may be imposed on the taxpayer by the Internal Revenue Service, and it cannot be used by any taxpayer for such purpose. No one, without express prior written permission may use or refer to any tax advice in this communication in promoting, marketing, or recommending a partnership or other entity, investment plan or arrangement to any other party.