US District Court issues mixed decision on disclosure of tax accrual workpapers

Washington National Tax Services
Litigation lasting more than three years between the IRS and Wells Fargo over access to tax accrual workpapers has been resolved by the trial court.  On June 4, the US District Court for the District of Minnesota issued an opinion concluding that the IRS was entitled to an issue-by-issue identification of Wells Fargo’s uncertain tax positions (UTPs), but that the recognition and measurement analysis included in Wells Fargo’s tax accrual workpapers with respect to those UTPs was protected by the work product doctrine.  The court also concluded that the IRS was not entitled to tax accrual workpapers relating to Wells Fargo’s state and local UTPs and that certain email documents were protected by the attorney-client privilege.


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