Client X has potential criminal tax exposure and is working with her lawyer to hopefully minimize the criminal tax consequences of her fraudulent return. Lawyer Lwishes to work with an accountant to voluntarily disclose X's proper liability by filing an amended return. Which of the following is an accurate statement? O a. Because of the Badaracco case, there is zero utility in filing an amended return to minimize risk of prosecution Ob. So long as Lawyer L enters into a Kovel relationship with an accountant an accountant can work directly for the client and bill X for her services O c. So long as the client files an amended tax return that is accurate in all material respects the IRS will generally be required to assess additional tax within three years of the IRS receiving the amended return. O d. So long as Lawyer Lenters into a Kovel relationship with an accountant, communications the accountant will have with the lawyer may be protected by the attorney client privilege