United States v. Sideman & Bancroft, LLP

Sideman, the legal representative for a taxpayer who was under criminal investigation by the IRS, appealed from the district court's order enforcing an IRS administrative summons to produce the taxpayer's documents. Sideman argued that producing the documents would be testimonial in violation of the taxpayer's Fifth Amendment rights. The district court's finding that the IRS could independently authenticate the tax records contained in the identified collection of boxes and folders currently held by Sideman was not clearly erroneous. Accordingly, the court held that the district court did not err in applying the foregone conclusion exception when enforcing Sideman's compliance with the summons. View "United States v. Sideman & Bancroft, LLP" on Justia Law