A bank’s request to depose three government witnesses prior to the evidentiary hearing on its motion to quash an IRS summons seeking its tax accrual work papers was improperly denied. The bank made a substantialshowing that enforcement of the summons might infringe on its right to invoke the work-product privilege. Moreover, in cases where the taxpayer is alleging thatthe government has an improper purpose for the summons discovery is appropriate and should be allowed.
Wells Fargo & Co., DC Minn., 2011-2 ustc ¶50,482
Other References: Code Sec. 7602
CCH Reference – 2011FED ¶42,827.16
CCH Reference – 2011FED ¶42,827.5068
Tax Research Consultant
CCH Reference – TRC IRS: 21,402.35