United States Ninth Circuit

In challenge to an Internal Revenue Service (IRS) administrative summons by defendant-law firm regarding one of its client's records, order enforcing the summons is affirmed, where the district court did not err in: 1) finding that the IRS could independently authenticate the individual taxpayer's 2007and 2008 tax records contained in the identified collection of boxes and folders currently held by defendant-law firm; and 2) applying the foregone conclusion exception of the Fifth Amendment when enforcing defendant-law firm's compliance with the summons.

Appellate Information

• Decided 01/08/2013
• Published 01/08/2013

Judges

• WALLACE

Court

• United States Ninth Circuit

Counsel