Legal Opinion

United States v. Baggot

Supreme Court of the United States

Decided June 30, 1983No. 81-1938PublishedCited by 200 opinions

1Opinion of the CourtJustice Brennan

In United States v. Sells Engineering, Inc., ante, p. 418, we decide today that in some circumstances the Government may obtain disclosure of grand jury materials for civil uses under Federal Rule of Criminal Procedure 6(e)(3)(C)(i) (hereinafter sometimes referred to as (C)(i)). The question in this case is whether an Internal Revenue Service investigation to determine a taxpayer’s civil tax liability is “preliminar[y] to or in connection with a judicial proceeding” within the meaning of that Rule. We agree with the Court of Appeals that it is not.

In May 1976, a special grand jury began…

2Cases cited10 opinions

  1. Douglas Oil Co. of Cal. v. Petrol Stops NorthwestSupreme Court of the United States · 1979
  2. In Re Grand Jury Proceedings United States of AmericaCourt of Appeals for the Third Circuit · 1962
  3. In Re Special February 1971 Grand Jury, Howard Jachimowski v. James B. Conlisk, Jr., Superintendent of PoliceCourt of Appeals for the Seventh Circuit · 1973
  4. Doe v. RosenberryCourt of Appeals for the Second Circuit · 1958
  5. In Re the Special February, 1975 Grand Jury. In Re the Special April, 1977 Grand Jury. Appeal of James E. BaggotCourt of Appeals for the Seventh Circuit · 1981

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3Cited by200 opinions

  1. Dahlstrom v. CommissionerUnited States Tax Court · 1985
  2. Clair S. Huffman v. Commissioner Of Internal RevenueCourt of Appeals for the Ninth Circuit · 1992
  3. United States v. Michael J. Corbitt, Pulitzer Community Newspapers, Inc., Intervenor-AppelleeCourt of Appeals for the Seventh Circuit · 1989
  4. Kluger v. CommissionerUnited States Tax Court · 1984
  5. United States v. John Doe, Inc. ISupreme Court of the United States · 1987

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