United States of America and Donald M. Cerra, Special Agent of the Internal Revenue Service v. John L. Beattie, Jr.

FRIENDLY, Circuit Judge:

This is an appeal by John L. Beattie,, Jr. (sometimes hereafter the taxpayer) from an order of the United States District Court for the Western District of New York pursuant to 26 U.S.C. § 7402(b) and § 7604(a), enforcing an Internal Revenue Service summons issued under 26 U.S.C. § 7602 despite Beattie’s claim of self-incrimination.

The summons, dated September 13, 1974, required Beattie to appear before Special Agent Donald M. Cerra in Rochester, New York, and to bring with him and produce for examination:

All original workpapers of Arthur Robeson, C.P.A. which are in…