Fu Investment Co., Ltd. v. Commissioner
United States Tax Court
104 T.C. 408 (1995)
- Written by Kate Luck, JD
Facts
The Internal Revenue Service (IRS) (defendant) determined that Fu Investment Co., Ltd., and Coco Palms Investment, Inc. (collectively, the investment companies) (plaintiffs) were liable for a tax deficit. The investment companies filed suit in federal district court challenging the IRS’s determination. The IRS contacted former employees of the investment companies, requesting interviews. The investment companies filed motions for protective orders requesting that the court prohibit the IRS from having ex parte communication with their former employees. The investment companies asserted that the former employees had spoken with the investment companies’ attorney during their employment and were knowledgeable of confidential attorney-client communications related to the subject of the case. The IRS stated that it would avoid eliciting privileged information from the former employees and would provide the investment companies with copies of its notes from the interviews.
Rule of Law
Issue
Holding and Reasoning (Dawson, J.)
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