United States v. Ackert

LEVAL, Circuit Judge:

The United States of America appeals from a decision of the district court (William I. Garfinkel, Magistrate Judge) in a tax summons enforcement proceeding, barring the Internal Revenue Service from questioning Respondent David A. Ackert, an investment banker, about his conversations with Paramount Corporation’s counsel, by reason of Paramount’s attorney-client privilege. We reverse.

BACKGROUND

The relevant facts are not in dispute. In 1989, Goldman, Sachs, and Co., an investment banking firm, approached Paramount with an investment proposal. The proposed transaction was…