When a lawyer’s advice is sought for both business purposes (such as tax compliance) and legal advice (advice on tax law), whether the communications are attorney-client privileged or not is tested by the “primary purpose” test–was the primary purpose of the communication legal or business advice?  (The court expressly declines to decide whether legal advice being “a” rather than “the” primary purpose is sufficient.)  The “because of” test used to determine whether a document is subject to the work product privilege is not to be applied to determining whether the attorney-client privilege applies in mixed use cases.