Defense and Privileges: The Kovel Accountant (Video) (Course Id 2674)

• Who is this course for?
  This course is designed for CPAs, tax professionals, and IRS Enrolled Agents seeking Continuing Professional Education (CPE) credits, particularly those interested in legal protections in tax matters.

• What is this course about or what problem does this course solve?
  The course explains Kovel agreements and how they extend attorney-client privilege to accountants, helping protect sensitive communications in tax-related legal situations.

• How can the knowledge from this course be used?
  Learners can use the knowledge to effectively implement Kovel agreements, understand the legal risks and benefits, and enhance client confidentiality during IRS scrutiny.

• Why is this course important to a CPA, Accountant, or IRS Enrolled Agent?
  It equips professionals with a deeper understanding of legal privileges, enabling them to better support attorneys and protect client interests in complex tax matters.

• When is this course relevant or timely?
  This course is especially relevant when handling cases involving potential legal exposure to the IRS or when legal confidentiality is crucial in tax practice.

• How is a course like this consumed or used?
  The course is delivered as a self-paced video with accompanying review and exam questions, accessible online without the need for additional materials.

In this presentation, tax attorney Mike DeBlis explains Kovel agreements and discusses the case that gave rise to them.

Video - NASBA QAS - NASBA Registry - IRS Enrolled Agents - 2674

Course Learning Objectives

1. How does the Kovel accountant concept enhance the attorney-client privilege compared to traditional accountant-client relationships?
2. What are the potential risks associated with using an original accountant in the context of a Kovel agreement?
3. In what ways can the distinction between the roles of the original accountant and the Kovel accountant affect the outcome of a case involving IRS scrutiny?
4. Why might a client resist the recommendation to hire a new accountant, and how can attorneys effectively address these concerns?
5. Discuss the implications of the Kovel agreement on the confidentiality of communications between a taxpayer and their accountant.
6. How does the Kovel case illustrate the importance of understanding the limitations of the attorney-client privilege in tax matters?
7. What steps should an attorney take to ensure that a Kovel agreement is properly executed and protects the client's interests?
8. In what scenarios might the privilege provided by Section 7525 be challenged, and what can be done to mitigate these challenges?
9. How does the work-product doctrine relate to the Kovel accountant, and what protections does it offer?
10. Considering the narrow scope of the accountant-taxpayer privilege, how can taxpayers safeguard their communications with their accountants?
11. How does the Kovel accountant framework compare to other methods of integrating legal and financial advice in tax matters?
12. What lessons can be learned from the Kovel case regarding the balance between legal obligations and the need for confidentiality in financial practices?

Chapter 1 - Defense and Privileges: The Kovel Accountant

Chapter 1 Review Questions