In Re Grand Jury Subpoena. (Four Cases) United States of America v. Under Seal, (Four Cases)

SPROUSE, Circuit Judge:

This appeal concerns information developed by a tax fraud investigation initiated by the Internal Revenue Service (IRS) and pursued by both the IRS and a federal grand jury. The investigation targeted appellants — a parent corporation, its subsidiaries, and several individual employees of the corporations. Records of two of the corporations were seized by IRS agents pursuant to search warrants and records of the other corporations by grand jury subpoenas. The records seized pursuant to search warrants were subsequently shown to agents in the Civil Division of the IRS.…