Office of Disciplinary Counsel v. Massey

We adopt the findings and of the board, but not its recommendation. The provisions of Section 60501, Title 26, U.S.Code are designed to provide the government with information to identify unreported income. United States v. Wilson (C.A.7, 1993), 985 F.2d 348, 350. Under federal law, respondent had a duty to refrain from attempting to structure a transaction to evade the requirement of filing IRS Form 8300.

An attorney is obliged to provide the information in the form unless the attorney can show that compliance would compromise confidential attorney-client communication. United States v.…