IRS has not previously filed substitute returns
March 25, 2014
How will the government force me to file returns?
March 25, 2014
Show all

Tax attorney representation when re-entering tax system

The non-filer would be wise to withhold any information from the trusted tax preparer initially because of the threat of criminal prosecution and the preparer’s lack of privilege. An attorney should be engaged prior to approaching the tax professional.

The tax attorney, trusted tax professional, and the client should first enter into a three-party agreement wherein the tax attorney retains the trusted tax professional to prepare the delinquent returns. In this manner information the trusted tax professional learns in the preparation of the returns, which is not disclosed on the returns themselves, will fall under the attorney-client privilege and thus can be protected from subsequent disclosure by the trusted tax professional.