United States v. BDO Seidman

RIPPLE, Circuit Judge.

Several unnamed clients of BDO Seid-man, LLP (“BDO”), a public accounting and consulting firm, appeal from the district court’s denial of their motions to intervene in an Internal Revenue Service (“IRS”) enforcement action against BDO.

The IRS had issued twenty summonses to BDO as part of its investigation of BDO’s compliance with Internal Revenue Code registration and list-keeping requirements for organizers and sellers of poten tially abusive tax shelters. See 26 U.S.C. §§ 6111, 6112. The clients sought to intervene to assert a confidentiality privilege regarding…