1. PUB Corp. is a publicly held company and for several years its certified audit has been done by Final 4, a nationally known accounting firm. Annabel Aggressive, certified public accountant, a recent graduate of a Master of Taxation program and the self-styled "fireball" of Final 4, has just received a summons from the IRS. Annabel worked on the certified audit of PUB Corp. and prepared the tax accrual workpapers regarding PUB Corp. The summons seeks production of the tax accrual workpapers, a step the agent has resorted to because Annabel refuses to produce them (or anything else if she can get away with it) voluntarily. Annabel knows that you are still a student in the Master of Taxation program and also knows that in your course you are discussing the Section 7525 privilege and the Arthur Young case, 465 U.S. 805 (1984), 84-1 USTC 9305, concerning a privilege for accountant's tax accrual workpapers. (See Chapter 7, IRS position on seeking accrual workpapers). Annabel wants to claim privilege solely to delay the agent in his audit. She wants to know whether her actions are prohibited by Circular 230