Fisher v. United States

In these two cases we are called upon to decide whether a summons directing an attorney to produce documents delivered to him by his client in connection with the attorney-client relationship is enforceable over claims that the documents were constitutionally immune from summons in the hands of the client and retained that immunity in the hands of the attorney.

I

In each case, an Internal Revenue agent visited the taxpayer or taxpayers1 and interviewed them in con*394nection with an investigation of possible civil or criminal liability under the federal income tax laws. Shortly after the interviews…