The IRS has issued a summons for the tax file held by CPA Ann Whitman for her clients, the Harberts. The file consists of paper and electronic spreadsheets in which Whitman detailed some tax computations using assumptions that the IRS would find to be “too aggressive.” In addition, the file includes notes from meetings with the Harberts, income and balance sheet data as to their personal assets, and other technical correspondence, including email messages. In a memo to the tax research file, summarize the current status of the law as to whether the privilege of confidentiality protects these documents from the government.