United States Ninth Circuit

Denial of estate and law firm's motion to quash an IRS summons issued to Bank of America in connection with an investigation into an abusive tax shelter is affirmed over claims that the district court erred when it held that: 1) penalties under certain statutory sections survived attorney's death; and 2) the attorney-client privilege did not protect the material requested from the Bank of America.

Appellate Information

• Argued 12/06/2006
• Decided 03/20/2007
• Published 03/20/2007

Judges

• SCHWARZER, District Judge., Before B. FLETCHER and McKEOWN, Circuit Judges, and WILLIAM W. SCHWARZER, District Judge.

Court

• United States Ninth Circuit

Counsel

• For Appellant:
  
• John M. Colvin, Chicoine & Hallett, P.S., Seattle, WA, for the appellants.


• For Appellees:
  
• Gretchen M. Wolfinger, Tax Division, U.S. Department of Justice, Washington, D.C., for the appellee.