Tax Return Confidentiality: Recent Developments

January 21, 2024  |  New York Law Journal

In 1976, Congress amended section 6103 of the Internal Revenue Code to prohibit the Internal Revenue Service from disclosing tax returns and tax return information except in limited circumstances. While the recent prosecution of a government contractor and a civil case brought by Hunter Biden have raised public awareness of section 6103’s prohibitions, practitioners have been litigating more nuanced disclosure issues for years. In his latest article for the New York Law Journal, Morvillo Abramowitz partner Jeremy H. Temkin discusses recent cases addressing exceptions to the general rule of confidentiality in civil litigation and in connection with investigations, as well as the application of a safe harbor shielding the government from liability for unauthorized disclosures.

Tax Return Confidentiality: Recent Developments (pdf | 184.65 KB)