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).
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