Documents in Tax Dispute Held Protected by Attorney-Client Privilege

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A magistrate judge for the U.S. District Court for the District of Nebraska rules in an employment tax case that correspondence between an attorney and a taxpayer that was turned over to the government by a third party—to whom the correspondence was also addressed—must be returned to the taxpayer or destroyed because it is protected under attorney-client privilege. The ruling comes in a dispute between the government and a taxpayer and his wife over nearly $2.4 million in unpaid employment taxes and concerns correspondence written by an attorney and addressed to the taxpayer and another individual.