However, the Court is of the opinion that where tax planning advice is sought from a lawyer, the legal advice prong of the [situation is different] . . here is a marked distinction between tax planning and income tax return preparation. Tax planning is concerned with current or future tax periods. It entails advising a client on how best to structure contemplated financial transactions, decisions, or occurrences from a tax consequences stand­point; the identification of the various means by which a particular tax objective of the client can be achieved; and other before-the-fact research and advice. * * *

Income tax return preparation, on the other hand, involves closed tax periods and entails evaluating the tax consequences of previously consummated transactions and occurrences; compiling the infor­mation pertinent to those transactions and events; categorizing, classifying, and otherwise organizing that information in a way which corresponds with the classifications and categories appearing on tax return forms; selecting among the various available tax forms; electing the most advantageous tax filing status; computing the final figures to be included an the taxpayer’s return on the basis of the raw information available; completing the tax return; and other after the-fact services ultimately aimed at satisfying the disclosure requirements for the tax period in question. Such informa­tion routinely furnished by taxpayers to their non lawyer income tax return preparers probably will not be protected by the privilege.more