Judging by the feedback we receive from our readers, the topic of workpapers and work product continues to be an area of major concern for many tax practitioners. For those who are interested in learning more about the topic, particularly in light of the D.C. Circuit’s recent decision in United States v. Deloitte LLP, I will be speaking on a webinar panel, U.S. v. Deloitte: Expansion of Work Product Doctrine in Tax Controversies, next Tuesday at 1pm (EDT). For prior TaxBlawg discussion of the Deloitte opinion, see here.
Together with Edward Froelich of Morrison & Foerster and Kevin Spencer of McDermott, Will & Emery, I will be discussing the implications of Deloitte for protecting tax documents, particularly in the context of responding to IRS summons and complying with the proposed Schedule UTP. It should be an interesting presentation, with a discussion of practical tips for navigating this constantly changing area.