Evergreen Trading, LLC v. United States
United States Court of Federal Claims
80 Fed.Cl. 122 (2007)
Relevant factsFree
Evergreen Trading, LLC (plaintiff) challenged tax penalties assessed for underpayments the government attributed to mischaracterized transactions. Evergreen resisted disclosing correspondence between it and its accountant that accompanied documents about the disputed transactions, claiming the correspondence was privileged.
IssueFree
Whether attorney-client privilege extends to protect communications between a taxpayer and its accountant when no separate accountant-client privilege exists under federal law.