Couch v. United States

On January 7, 1970, the Government filed a petition in the United States District Court for the Western District of Virginia, pursuant to 26 U. S. C. §§ 7402 (b) and 7604 (a),1 seeking enforcement of an Internal Revenue summons in connection with an investigation of petitioner’s tax liability from 1964-1968. The summons was directed to petitioner’s accountant for the production of:

“All books, records, bank statements, cancelled checks, deposit ticket copies, workpapers and all other pertinent documents pertaining to the tax liability of the above taxpayer.” 2

The question is whether the…