29) The IRS has issued a summons for the tax file held by CPAAnn Whitman for her clients, the Harberts. The file consists ofpaper and electronic spreadsheets in which Whitman detailed sometax computations using assumptions that the IRS would find to be“too aggressive.” In addition, the file includes notes frommeetings with the Harberts, income and balance sheet data as totheir personal assets, and other technical correspondence,including email messages. In a memo to the tax research file,summarize the current status of the law as to whether the privilegeof confidentiality protects these documents from thegovernment.