American Bar Association Section of Taxation 2014 May Meeting

Taxation attorney Josh Husbands spoke at the American Bar Association Section of Taxation Meeting on a panel titled "Serving Two Masters: The Practitioner's Duties Under Circular 230 and As an Advocate for a Client."

Circular 230 requires a practitioner to provide all information requested by the IRS "unless privileged." The IRS routinely makes extremely broad requests for information that may be irrelevant and are, at a minimum, burdensome and expensive to produce, but not privileged. How does the practitioner resolve the tensions between duties imposed by Circular 230 and those imposed under other ethical rules to advocate for the client’s interest in avoiding unnecessary or excessive effort and cost?