ROGER D. FOLEY, Chief Judge.
On July 8, 1964, C. L. Beason and J. R. Chamberlain, Special Agents of the internal Revenue Service, Intelligence Division, then conducting an investigation into the income tax liability of Carl Cohen and his wife, called upon Cohen and made demand to examine his tax records for the years 1958 through 1963, inclusive. Cohen advised the Agents that the tax records were in the possession of his accountant, Samuel Berke, of Beverly Hills...
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