United States of America and Richard M. Humann, Revenue Agent of the Internal Revenue Service v. Elton H. Silkman

Elton H. Silkman, taxpayer, appeals from an order of the District Court directing his compliance with an Internal Revenue summons seeking records necessary to audit his 1973 return and to prepare his 1974 return. The summons in question was issued by an Internal Revenue agent when the taxpayer failed to comply with an investigation seeking to establish his correct tax liabilities. When the taxpayer refused to produce the requested records claiming he was privileged to withhold them under the Constitution, the government petitioned the District Court for judicial enforcement of the summons. It…