STJ Diana L. (“Sidewalks of New York”) Leyden reaches back to Han Suyin’s 1952 novel in a broad-spectrum overview of privilege in its many-splendored forms. Marc Worrall & Sue J. Worrall, Docket No. 14734-23, filed 4/14/25, have ten (count ’em, ten) trusty attorneys, all burning and churning by day and night through every form of privilege (except only intraspousal, clergy-penitent, and patient-physician), but STJ Di stays with them and their ten (count ’em, ten) IRS adversaries for seventeen (count ’em, seventeen) pages.

STJ Di invokes a wide view of Section 7525 qualifying tax advice, so check out Order, at pp. 8-12. Mere filing instructions and statements of the law and regs unrelated to specifics don’t get it, likewise business advice isn’t enough.

A sculpted conflict waiver can earn work product privilege if tied in to reasonably anticipated litigation.

Attorney-client, of course, is the main course, so if you need apposite somber reasoning and copious citation of precedent for your next brief, STJ Di and the 20 trusty attorneys lay it all on you in the Order, at pp. 3-8.

This is a microcaptive case, featuring exotic coverages for Marc’s & Sue’s lobstering company. Should make for a fascinating opinion, when all the discovery is over.