2. Attorney-Client Privilege
o Privilege holder is, or sought to be, a client;
o Communication was to made:
o To a member of the bar or subordinate, and
o Made in connection with them acting as a lawyer,
o Relates to fact attorney of which attorney was informed:
o By the client
o Without the presence of strangers
o For the purpose of securing primarily either:
o An opinion of law,
o Legal services, or
o Assistance in some legal proceeding, and not
o For the purpose of committing a crime or tort, and
o The privilege has been
o Claimed, and
o Not waived by the client.
o See also IRC § 7525
3. Record Keeping Requirements
Every person liable for any tax imposed
by this title, or for the collection thereof,
shall keep such records, render such
statements, make such returns, and
comply with such rules and regulations
as the Secretary may from time to time
prescribe.
4. Record Keeping Requirements
(a) ... any person required to file a return of information with
respect to income, shall keep such permanent books of
account or records, including inventories, as are sufficient
to establish the amount of gross income, deductions,
credits, or other matters required to be shown by such
person in any return of such tax or information.
(e) The books or records required by this section shall be
kept at all times available for inspection by authorized
internal revenue officers or employees, and shall be
retained so long as the contents thereof may become
material in the administration of any internal revenue law.
Treas. Reg. § 1.6001-1
9. Worker Classification
Concerns
o Reciprocal State Employment Tax
Matters
o Section 530
o Trust Fund Recovery – IRC § 6672
o Voluntary Worker Classification
Settlement Program (VCSP)