United States v. Richey

OPINION

M. SMITH, Circuit Judge:

The Internal Revenue Service (IRS or Government) challenges the district court’s ruling denying its motion to enforce a summons against Defendant-Appellant, Mark Richey, seeking production of an appraisal work file. The IRS contends that the district court erred when it found that the summons was not issued in good faith, and that the appraisal work file was protected by the attorney-client privilege and work-product doctrine.

We hold that the IRS summons was issued in good faith, and that the district court erred in finding that Richey’s entire appraisal work…