Legal Opinion

Cavallaro v. United States

District Court, D. Massachusetts

Decided July 27, 2001No. 1:99-cv-12625PublishedCited by 7 opinions

1Opinion of the Court

MEMORANDUM AND ORDER

SARIS, District Judge.

I. INTRODUCTION

This action involves an Internal Revenue Service (“IRS”) proceeding to determine the correct tax liability of petitioners William and Patricia Cavallaro (“the Cavalla-ros”) for the years 1987 through 1996. The IRS has issued a third-party record-keeper summons to the accounting firm of Ernst & Young seeking documents the accounting firm created or received while working on estate tax and corporate merger issues with petitioners’ attorney at the law firm of Hale and Dorr.

The Cavallaros have filed a motion to quash the IRS summons on the…

2Cases cited25 opinions

  1. Upjohn Co. v. United StatesSupreme Court of the United States · 1981
  2. Fisher v. United StatesSupreme Court of the United States · 1976
  3. United States v. Louis KovelCourt of Appeals for the Second Circuit · 1961
  4. United States v. Arthur Young & Co.Supreme Court of the United States · 1984
  5. James J. Kevlik v. David B. Goldstein, Town of DerryCourt of Appeals for the First Circuit · 1984

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3Cited by7 opinions

  1. Cavallaro v. United StatesCourt of Appeals for the First Circuit · 2002
  2. Louisiana Municipal Police Employees Retirement System v. Sealed Air Corp.District Court, D. New Jersey · 2008
  3. 10x Genomics, Inc. v. Celsee, Inc.District Court, D. Delaware · 2020
  4. Carvallaro v. United StatesCourt of Appeals for the First Circuit · 2002
  5. Chabot v. Walgreens Boots Alliance, Inc.District Court, M.D. Pennsylvania · 2021

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