Legal Opinion
Stephen Tornay, Galene Tornay v. United States of America A.R. Demeter, Special Agent, Internal Revenue Service
Court of Appeals for the Ninth Circuit
Decided February 22, 1988No. 86-4432PublishedCited by 91 opinions
1Opinion of the Court
EUGENE A. WRIGHT, Circuit Judge:
We must decide if an IRS summons to an attorney for information regarding fees paid by his clients is protected by the attorney-client privilege, or violates the Sixth Amendment right to counsel or the Fifth Amendment right to due process.
BACKGROUND
Stephen and Galene Tornay were the subject of an investigation by the Internal Revenue Service to determine their federal tax liability for tax years 1978 through 1983. The IRS sought to establish tax liability on a net worth, net expenditure basis. It issued summonses to three Oregon attorneys, whom the Tornays had…
2Cases cited32 opinions
- Kirby v. IllinoisSupreme Court of the United States · 1972
- Fisher v. United StatesSupreme Court of the United States · 1976
- United States v. Winston Bryant McConneyCourt of Appeals for the Ninth Circuit · 1984
- United States v. PowellSupreme Court of the United States · 1964
- United States v. GouveiaSupreme Court of the United States · 1984
27 more not listed; retrieve them via the Exa API.
3Cited by91 opinions
- United States v. Robert W. Ritchie, Personally and in His Capacity as a Partner/officer of Ritchie, Fels & Dillard, P.C.Court of Appeals for the Sixth Circuit · 1994
- In Re Grand Jury Investigation. United States of America v. The Corporation 1Court of Appeals for the Ninth Circuit · 1992
- United States v. Raymond M. GrayCourt of Appeals for the Ninth Circuit · 1989
- Robert L. Clarke, Comptroller of the Currency v. American Commerce National Bank, Anaheim, CaliforniaCourt of Appeals for the Ninth Circuit · 1992
- Tommy v. Greenhow v. Secretary of Health & Human ServicesCourt of Appeals for the Ninth Circuit · 1988
86 more not listed; retrieve them via the Exa API.