I have attached a document that I would like help on.

1. Last year, Bill’s 20x1 tax return was audited by the IRS, with certain adjustments to which he has agreed and paid the additional tax. Last week, Bill received a letter from the IRS stating that it wanted to examine his 20x2 return and that in connection with that audit he should make available all his books and records for 20x1 in the event the IRS wished to reexamine that year. Bill was outraged and thought he had made a deal with the IRS about 20x1, a deal on which it is now reneging. Can the IRS do this to Bill? Explain.

1. Does the IRS have the power to summons records in a foreign country? Explain.

1. The IRS has ordered your client to present all his books and records for review in connection with an audit of his tax returns for the past five years. In this request, the agent has also asked that the taxpayer prepare a chronological summary of all deposits to his various checking accounts. The client complains to you that obtaining checking account statements for such a long period and preparing the summary will be costly and time consuming. What is your advice?

1. Your client has received a letter (not a summons) from the IRS that requests that he appear before the IRS at a certain date and time to give testimony about a third party. Your client says it will be expensive for him to go to the meeting and wants you to go instead. Can you represent him? Explain. Would your answer change if the letter were instead a summons?

1. Your client has just received an IRS summons to appear for an interview. In the form of a letter to the client, describe, in general, what will occur.

1. Your client has just received a summons from the IRS to appear before it with all his bank statements for the last three years. What possible objections might you raise to such a summons? Explain each briefly.

1. How does a taxpayer stop a third-party record-keeper from handing over information summoned from that record-keeper by the IRS?

1. The IRS can summon only relevant material. What is meant by the term “relevant” for this purpose?

1. Discuss what constitutional challenges a taxpayer could make to an IRS summons.

1. How does the attorney-client privilege affect a summons under I.R.C. § 7601?

1. The IRS summons Forms 1099 from Bank B, which responds that the information is already possessed by the IRS. Can the summons be enforced?

1. The Justice Department is currently conducting a criminal prosecution against Taxpayer in connection with his 20x2 income tax return. Can the IRS issue a summons regarding Taxpayer’s 20x2 tax liability?

1. Attorney A is retained by B to prepare B’s tax return. A is later summoned to testify regarding B’s tax returns and to produce books and records relating to his preparation of the return. A refuses to comply with the summons based on the attorney-client privilege. Can the summons be enforced against A? Explain.

1. During an independent audit, it is discovered that Corporation X has made payments to foreign government officials to secure business with a foreign country. The matter is brought to the attention of X’s in-house counsel, who consults with X’s outside counsel. In-house counsel prepares and distribute investigation questionnaires to managers, who are instructed to treat the questionnaires as highly confidential. Responses are sent directly to X’s outside counsel. Based on the reports, X voluntarily discloses the preliminary reports to the IRS, which immediately begins an investigation. The IRS subsequently issues summons seeking all documents relating to the payments, including the questionnaires. X refuses to comply. What will be the result? Explain fully.