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U.S. v. RITCHIE

No. 92-6393.

15 F.3d 592 (1994)

UNITED STATES of America, Petitioner-Appellee, v. Robert W. RITCHIE, personally and in his capacity as a partner/officer of Ritchie, Fels & Dillard, P.C., Respondent-Appellant.

United States Court of Appeals, Sixth Circuit.

Decided February 3, 1994.

Rehearing and Suggestion for Rehearing Denied April 4, 1994.

Attorney(s) appearing for the Case

Gary R. Allen, Acting Chief (briefed), Charles E. Brookhart, John A. Dudeck (argued), U.S. Dept. of Justice, Appellate Section Tax Div., Washington, DC, David G. Dake, Asst. U.S. Atty., Knoxville, TN, Jose Francisco De Leon, U.S. Dept. of Justice, Tax Div., Washington, DC, for petitioner-appellee.

W. Thomas Dillard (argued and briefed), Ritchie, Fels & Dillard, Knoxville, TN, Gerald H. Goldstein (argued and briefed), San Antonio, TX, for respondent-appellant.

Before: NELSON and BATCHELDER, Circuit Judges, and MATIA, District Judge.

Rehearing and Suggestion for Rehearing En Banc Denied April 4, 1994.

ALICE M. BATCHELDER, Circuit Judge.

In this case we are asked to decide whether an IRS summons issued to a lawyer and instructing that the lawyer disclose the identity of and fee arrangement with certain cash-paying clients can survive a challenge by the lawyer that such information is protected from disclosure by the Fifth and Sixth Amendments. We...

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