You are a accountant. Your client, an individual, hires you to investigate the tax treatment...
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You are a accountant. Your client, an individual, hires you to investigate the tax treatment of a particular transaction reported on a prior return (that another accountant prepared). The client is concerned that the treatment was erroneous and, therefore, she might be subject to some kind of penalty. Is your tax advice memorandum privileged under either the accountant's privilege or the work-product doctrine? How would your answer change if the client's attorney hies you?
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