Joshua D. Smeltzer Quoted Again in Tax Notes Article Entitled “Texas Law Firm Seeks Rehearing of Identity Privilege Claim”

June 11, 2020 by

Joshua D. Smeltzer, tax partner at Brown Fox PLLC, was quoted in a recent Tax Notes article discussing a recent petition for rehearing by a Texas law firm where the court required the firm to turn over information on clients with offshore structures in response to an IRS John Doe summons.

“Although privilege issues are important, getting a rehearing en banc is always an uphill battle that is seldom won.” ~Joshua Smeltzer, tax partner
Excerpts from the article are listed below:

“’Whether the Fifth Circuit will agree to rehear the case is anyone’s guess,’ said Joshua D. Smeltzer of Brown Fox PLLC, who noted that it’s becoming increasingly rare for courts to grant petitions for rehearing en banc.”

“‘Although privilege issues are important, getting a rehearing en banc is always an uphill battle that is seldom won,’ said Smeltzer.”

A link to the full article is here.

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