Legal Opinion
United States of America and Howard W. George, Special Agent, Internal Revenue Service v. Donald E. Cote
Court of Appeals for the Eighth Circuit
Decided February 29, 1972No. 71-1202 to 71-1204PublishedCited by 94 opinions
1Opinion of the Court
LAY, Circuit Judge.
The issue on appeal concerns the enforcement of summonses issued under 26 U.S.C. § 7602 to Donald Cote, a certified public accountant, and Thomas Murphy, a lawyer. The taxpayers, John C. and Evelyn Erickson, were allowed to intervene. Both Murphy and Cote refused to produce any workpapers used in preparing taxpayers’ original and amended returns for the years 1966, 1967 and 1968. The sole issue is whether the attorney-client privilege prevents disclosure of memoranda and working papers prepared by the accountant at the attorney’s request for purposes of giving legal advice.…
2Cases cited16 opinions
- United States v. Louis KovelCourt of Appeals for the Second Circuit · 1961
- Edward E. Colton and Lillian Kaltman v. United States of America, United States of America v. Edward E. ColtonCourt of Appeals for the Second Circuit · 1962
- Brown v. United StatesSupreme Court of the United States · 1928
- Olender v. United StatesCourt of Appeals for the Ninth Circuit · 1954
- United States v. Walter F. Tellier, Albert Joseph Proctor, Elton B. Jones and Alaska Telephone CorporationCourt of Appeals for the Second Circuit · 1958
11 more not listed; retrieve them via the Exa API.
3Cited by94 opinions
- In Re Sealed CaseCourt of Appeals for the D.C. Circuit · 1982
- Burke v. RegaladoCourt of Appeals for the Tenth Circuit · 2019
- In Re Grand Jury Subpoena Duces Tecum Dated September 15, 1983 Marc Rich & Co. A.G., Intervenor-Appellant v. United StatesCourt of Appeals for the Second Circuit · 1984
- United States v. DavisCourt of Appeals for the Fifth Circuit · 1981
- United States v. JonesCourt of Appeals for the Fourth Circuit · 1982
89 more not listed; retrieve them via the Exa API.