Hodges v. United States Government

ALVIN B. RUBIN, Circuit Judge:

The Internal Revenue Service issued a summons commanding an accountant to produce records pertaining to a taxpayer’s business. The accountant and the taxpayer’s law firm which had hired him resisted production, and the taxpayer appeared at the proceedings, but refrained from intervening in them, as he had a statutory right to do, presumably because intervention would toll the statute of limitations on assessment of any tax deficiency. After appealing a district court ruling commanding the production of the records, the taxpayer now seeks for the first time, after…