NYC Tax Advocates

My photo
Specializing in IRS and NYS Tax Representation. Workers Compensation Audits, Payroll, Sales and Income Tax representation for Businesses, Individuals, Restaurants and Construction Companies. Civil and Criminal Workers Comp Audit representation includes: NYSIF Examinations, Premium Disputes, Employee Misclassification, Underreporting, Unreported Income, and Failure to Keep Accurate Payroll Records.

Friday, February 3, 2017

What the Hell is a Kovel Letter?





In a nutshell, a “Kovel letter” is a form that our tax firm ("Selig & Associates") uses to place an accountant (or other non-attorney) under the protection of the attorney-client privilege. Without this agreement securely in place, communications between the client (you) and the accountant (or non-attorney assistant) would not be protected from the IRS et al
FYI the so-called “accountant-client privilege” if any does not apply to criminal matters, e.g. failure to file, underreporting, falsified documents, etc
The letter we prepare applies to Criminal and Civil tax cases, and is called a "Kovel Letter" and because of it’s namesake “United States v. Kovel, 296 F.2d 918 (2d Cir. 1961)
Nota bene, there are significant limitations to the Kovel Doctrine, and as such, practicing attorneys may want to review inter alia United States v. Adlman, 68 F 3d 1495 (2nd Cir. 1995).

No comments:

Post a Comment

Selig & Associates is a boutique Tax Representation and Risk Management Firm specializing in unpaid tax obligations and commercial insurance coverage

  Tax Advocacy      Federal Tax Practitioner, CPCU and Attorney. Practicing before the Internal Revenue Service and New York State Departmen...