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UNITED STATES v. WIDELSKI

No. 71-1089.

452 F.2d 1 (1971)

UNITED STATES of America and Bruce B. Mack, Revenue Agent, Internal Revenue Service, Petitioners-Appellees, v. Richard J. WIDELSKI and Mary C. Widelski, Respondents-Appellants.

United States Court of Appeals, Sixth Circuit.

December 17, 1971.

Attorney(s) appearing for the Case

Joseph F. Dillon, Detroit, Mich., for appellants; Raymond & Fletcher, Detroit, Mich., on brief.

John J. Raymond, Joseph F. Dillon, Detroit, Mich., of counsel.

John M. Brant, Tax Div., Dept. of Justice, Washington, D. C., for appellees; Johnnie M. Walters, Asst. Atty. Gen., Meyer Rothwacks, Crombie J. D. Garrett, John P. Burke, John M. Brant, Attys., Dept. of Justice, Tax Div., Washington, D. C., on brief.

Ralph B. Guy, Jr., U. S. Atty., Detroit, Mich., of counsel.

Before PHILLIPS, Chief Judge, and WEICK and EDWARDS, Circuit Judges.

PHILLIPS, Chief Judge.

An accountant prepared income tax returns for the taxpayers for the years 1949-59. The original and a carbon copy of each return were transmitted to the taxpayers at the appropriate time for signing and filing. The accountant retained for his files a carbon copy of each tax return and the related work papers. The accountant's copy of the returns were transferred by him to the taxpayers at their request after a tax investigation had begun.

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