United States v. Hodgson
United States Court of Appeal for the Tenth Circuit
492 F.2d 1175 (1974)

- Written by Kate Luck, JD
Facts
A special agent for the Internal Revenue Service (IRS) (plaintiff) was investigating the tax liability of Leroy Dale Hines. The IRS issued a summons to Hines’s lawyer, Paul Hodgson (defendant), requesting records of charges of legal fees to Hines and payments received from Hines for legal services. Hodgson declined to comply with the summons, asserting the attorney-client privilege. The IRS petitioned the district court to enforce the summons. After conducting hearings on the issue at which the IRS special agent testified, the district court determined that the records sought were protected by attorney-client privilege. The IRS appealed.
Rule of Law
Issue
Holding and Reasoning (Breitenstein, J.)
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