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Legal Opinion

United States of America Bradley P. Whites, Special Agent, Internal Revenue Service v. Joseph P. Bornstein

Court of Appeals for the Fourth Circuit

Decided November 2, 1992No. 92-1170PublishedCited by 31 opinions

1Opinion of the Court

OPINION

ERVIN, Chief Judge:

After the Internal Revenue Service (“IRS”) issued a subpoena relating to a tax return prepared by Joseph Bornstein, Born-stein refused to turn over certain documents, claiming that the attorney-client privilege and the work product doctrine protected them. The withheld documents included documents Bornstein’s clients gave to him and workpapers an accountant prepared for him. Without reviewing the documents in camera, the district court ruled that the attorney-client privilege applied and denied enforcement of the summons. On appeal, the IRS argues that the district…

2Cases cited8 opinions

  1. United States v. PowellSupreme Court of the United States · 1964
  2. United States v. Louis KovelCourt of Appeals for the Second Circuit · 1961
  3. United States v. DavisCourt of Appeals for the Fifth Circuit · 1981
  4. United States of America and Revenue Agents Clarence H. Isabel and John S. Reid of the Internal Revenue Service v. The El Paso CompanyCourt of Appeals for the Fifth Circuit · 1982
  5. National Union Fire Insurance Company of Pittsburgh, Pa. v. Murray Sheet Metal Company, Incorporated, and Arkwright Mutual Insurance CompanyCourt of Appeals for the Fourth Circuit · 1992

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3Cited by31 opinions

  1. Cavallaro v. United StatesCourt of Appeals for the First Circuit · 2002
  2. United States v. Richard A. Frederick, and Randolph W. Lenz, Karin Lenz, and Kcs Industries, Inc., InterveningCourt of Appeals for the Seventh Circuit · 1999
  3. Kinetic Concepts, Inc. v. Convatec Inc.District Court, M.D. North Carolina · 2010
  4. In re Grand Jury ProceedingsCourt of Appeals for the Seventh Circuit · 2000
  5. Ferko v. National Ass'n for Stock Car Auto Racing, Inc.District Court, E.D. Texas · 2003

26 more not listed; retrieve them via the Exa API.

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