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Related to memoranda: memorandums, circulars
See: calendar
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More specifically, the increased frequency and importance of presidential memoranda suggests changing incentive structures have contributed to a corresponding reduction in executive orders.
First, I consider presidential memoranda in the context of unilateral action theory, arguing they constitute additional observations of the theory's outcome of interest.
In sustaining Yum's appeal, the Sixth Circuit followed Adlman II in defining documents prepared "in anticipation of litigation" as "prepared or obtained because of the prospect of litigation" and found that the work-product doctrine protected the two memoranda because the taxpayer established, based on surrounding facts and circumstances in addition to the substance of the documents themselves, that the documents were prepared in anticipation of litigation.
7) Thus, had Yum's work-product claim arisen in the context of Tax Court litigation, the IRS might well have secured the two KPMG memoranda.
Many practitioners have expressed concern that their clients will make a blanket waiver of privilege by disclosing all opinions or memoranda that provide a legal analysis of the tax shelter transaction.
The investors said they had relied on the offering memoranda in their decision to invest.
Although arguably Technical Advice Memoranda should not be issued where factual agreement does not exist, TEI recognizes that TAMs serve a valuable purpose in the tax compliance process.
The district court ruled in the IRS's favor, finding that the memoranda were not protected under either privilege.
We recognize that pending litigation about whether field service advice memoranda must be disclosed pursuant to section 6110 of the Internal Revenue Code may preclude a fullscale discussion of this topic.
Among the factors cited by the Service were: (1) the CPA firm's invoices did not specifically distinguish the charge for preparing the memorandum from the other work it performed in connection with the transaction; (2) the memoranda or summaries of their conclusions were communicated to corporate officials other than Adlman (presumably these officials were not attorneys); and (3) there was no contemporaneous documentation (e.