Overview
Law360 quoted Larry Hill in an October 4 article titled "Justices Won't Review IRS Summons For Firm's Client List" and an October 5 article titled "IRS Win In Law Firm Summons Row May Undermine Privilege." The articles discuss the US Supreme Court’s decision to decline to review a Fifth Circuit opinion that allowed the IRS to proceed with a summons to obtain the identities of clients believed to have possibly used a law firm’s advice to hide income offshore.
Hill was one of the authors of an amicus brief submitted by the American College of Tax Counsel that petitioned the Supreme Court for a Writ of Certiorari to review of a Fifth Circuit decision. He says of the Supreme Court’s denial of the Cert. petition, "I don't think it's going to ultimately discourage confidential communications between clients and their lawyers, but I do think that there are opportunities for the John Doe summons authority of the IRS to be potentially abused."
In the October 4 article Hill states, "Obviously I'm disappointed that the Supreme Court did not weigh in on the issue because I think it's very important in the context of the attorney-client relationship."
Both articles can be read at Law360 on October 4 and October 5. (subscriptions required)
