Michael Kelleher

Michael Kelleher

McDermott Will & Emery

Contact  |  View Bio  |  RSS

Latest Publications


Tax Court Extends Implied Waiver of Privilege to Taxpayers’ State of Mind Penalty Defense

The U.S. Tax Court concludes in AD Investment 2000 Fund LLC v. Commissioner that a taxpayer’s assertion of a state of mind penalty defense waives the attorney-client privilege with respect to tax opinions provided to the...more

4/28/2014 - Attorney-Client Privilege Privilege Waivers Tax Court

1 Results
View per page
Page: of 1
Popular Topics by This Author