Dallas L. Holifield v. United States

KANNE, Circuit Judge.

Petitioner-appellant, Dallas Holifield, challenges the propriety of the district court’s dismissal of his petition to quash an IRS summons for the production of documents which had been served upon his attorney. 689 F.Supp. 865. He argues, as he did below: (1) that the information requested by the summons is protected by the attorney-client privilege; (2) that the enforcement of the summons will jeopardize his sixth amendment right to counsel; and, (3) that the issuance of the summons itself constituted an abuse of the summons process in that the IRS did not comply with…