United States v. Hodgson

492 F.2d 1175 (1974)

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United States v. Hodgson

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

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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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