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Ninth Circuit Holds that Fifth Amendment Does Not Shield Taxpayer's Attorney from Forced Production of Client-Taxpayer's Records

Applying the “foregone conclusion” exception to the Fifth Amendment privilege against self-incrimination, the Ninth Circuit held on January 8, 2013, that the IRS could force a taxpayer’s criminal defense attorney to turn over...more

Ninth Circuit Interprets Fifth Amendment’s “Foregone Conclusion” Exception in IRS Summons Enforcement Case

On January 8, 2013, the United States Court of Appeals for the Ninth Circuit affirmed the decision of the U.S. District Court for the Northern District of California in the case of United States v. Sideman & Bancroft LLP. ...more

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