A 2004 e-mail could come back to haunt the Internal Revenue Service in its case against 16 former KPMG executives accused of selling questionably legal tax shelters.

The e-mail, which was read aloud to the New York Times over a phone call, says KPMG might not have to register certain tax shelters with the agency, including the so-called Blips shelter at the heart of the government's case.

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