Tornay v. United States
United States Court of Appeals for the Ninth Circuit
840 F.2d 1424 (1988)
- Written by Jamie Milne, JD
Facts
The Internal Revenue Service (IRS) (defendant) was investigating Stephen and Galene Tornay (plaintiffs) to determine their tax liability for 1978 to 1983. As part of the investigation, the IRS issued summonses to three Oregon attorneys hired by the Tornays in relation to a 1983 criminal conviction. The summonses sought information regarding the attorney’s fees paid by the Tornays. When the attorneys provided that information to the IRS, the Tornays fired them. The Tornays then hired Seattle attorney Robert Wayne. The IRS issued a similar summons to Wayne, but Wayne refused to comply. The Tornays filed a petition to quash the summons, arguing that requiring Wayne to provide the requested information would violate the attorney-client privilege. They also stated that if Wayne was forced to comply, then they would fire him. The district court denied the Tornays’ petition, and they appealed to the Ninth Circuit.
Rule of Law
Issue
Holding and Reasoning (Wright, J.)
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