Lessons In Keeping Accountant-Client Emails Privileged

By Mark Leeds and Bruce Wilson (December 13, 2018, 4:33 PM EST) -- The old legal saw "hard facts make bad law" has been acknowledged since at least 1837.[1] This maxim means that it is difficult to extract general rules of application from cases in which the facts are particularly muddied. Muddied facts certainly surrounded the criminal charges leveled against a taxpayer, a lawyer, in United States v. Adams[2] for allegedly "engag[ing] in a scheme and artifice to defraud investors" in two related companies, Apollo Diamond Inc. and Apollo Gemstone Corporation, together referred to below as "Apollo."[3]...

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