Hofstra Law Review


As stated in Part I, enthusiasm for the Symposium was stimulated by the recent Supreme Court case of Couch v. United States. A thorough analysis of the Court's reasoning in Couch is a necessary prerequisite to an understanding of what procedures should be established by accountants, attorneys, and others involved in preparing federal income tax returns or representing individual taxpayers in federal civil or criminal income tax fraud investigations or litigation to maximize the protection of the taxpayer's legal rights and privileges.

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