United States of America, and Eugene Nepveaux, Revenue Officer of Internal Revenue v. Thomas A. Moore, M.D.

In this case we are asked to determine whether a “physician (psychotherapist-patient privilege” protects information that the Internal Revenue Service is attempting to obtain from the defendant/appellant, Dr. Thomas A. Moore. Dr. Moore contends that the district court erred by enforcing the IRS summons in this case. We hold that there is no privilege protecting the information sought by the IRS. We affirm.

I

The appellant, Dr. Moore, is a practicing psychiatrist in Houma, Louisiana. Dr. Moore did not file federal income tax returns for the years 1977 through 1987 and has made no payments of his…