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A practitioner may not interfere with any proper and lawful effort by the Internal Revenue...

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Accounting

A practitioner may not interfere with any proper and lawful effort by the Internal Revenue Service to obtain any record or information unless:
The practitioner doesn't believe the information is pertinent to the case
The practitioner only has the information in a digital state
The practitioner believes that the information will implicate his client in illegal activity
The practitioner believes in good faith that the record or information is privileged

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