Abstract
Excerpt: During the 20th century, a tax opinion stamped ³Attorney-Client Privilege´ provided the client with a certain degree of security. IRS policy accepted the notion that the document was in fact privileged if it was stamped ³privileged.´ 1 At that time, the IRS was almost intimidated by any claim of privilege, particularly if the document involved a lawyer. If a lawyer had an opinion, the agents would not try to seek it. They would not check whether there was a waiver. They would not ask what the contents were, which they were entitled to get in a generalized fashion on a privilege log. Unfortunately, this notion provided clients with a false sense of security, and as we moved into the 21st century, the attorney-client privilege seems to have lost its nobility.
