United States v. Ralph Lockyer

WILLIAM E. DOYLE, Circuit Judge.

This is an income tax fraud prosecution in which the government seeks a reversal of a judgment of the district court which suppressed all of the evidence and dismissed a four-count complaint. The essential basis was that the Internal Revenue agent had conducted a criminal rather than a civil investigation prior to his referring the case to the special agent, Intelligence Division, and had done so without warning the defendant-appel-lee as to his rights and had thus violated the internal administrative regulation of the Revenue Service contained in one of its…