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Abstract
Section 7525(a) referred to the Uniform Application to Taxpayer Communications with Federally Authorized Practitioners. However, while the word uniform was used, the statute itself contained specific limitations contradicting the term. The general statutory rule was: With respect to tax advice, the same common law protections of confidentiality which apply to a communication between a taxpayer and an attorney shall also apply to a communication between a taxpayer and any federally authorized tax practitioner to the extent the communication would be considered a privileged communication if it were between a taxpayer and an attorney. The subsections of Section 7525, however, defined a number of limitations: 1. Privilege only can be asserted in any noncriminal tax proceeding in federal court brought by or against the United States. 3. The privilege is limited only to tax advice. 4. The privilege does not apply to any written communication between a federally authorized tax practitioner and a director, shareholder, officer or employee, agent or representative of a corporation in connection with the promotion of a direct or indirect participation of such corporation in any tax shelter.