• Kovel Arrangement To Defend IRS Joint Criminal/Civil Investigation

    From MSA@21:1/5 to All on Sun Jul 9 17:10:53 2023
    Hi everyone hope all is well. This is a very esoteric question. I'm lead Defense Counsel on an IRS Joint Criminal and Civil investigation. I want to bring in a new CPA to do some forensic work in the hope it benefits the client but I want to set this up
    using a Kovel Letter arrangement among Attorney/Accountant/Client.

    Have any of you participated in such Legal Defense structuring? Have Kovel arrangements, which have been "around" since I was an Attorney at IRS, been challenged at any level of an investigation up to and including issuing a Subpoena for the testimony
    etc. of a "Kovel-ized" Accountant?

    I of course will intensify my Research if I decide to go that route, but for now any informed experiential feedback would be helpful. thanks in Advance.

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