UNITED STATES v. COUCH

No. 14546.

449 F.2d 141 (1971)

UNITED STATES of America, and Edward F. Jennings, Special Agent, Internal Revenue Service, Appellees, v. Lillian V. COUCH, Appellant.

United States Court of Appeals, Fourth Circuit.

October 12, 1971.


Attorney(s) appearing for the Case

John G. Rocovich, Jr., Roanoke, Va. (Claude D. Carter and Martin, Hopkins, & Lemon, Roanoke, Va., on the brief), for appellant.

Joseph M. Howard, Atty., Department of Justice (Johnnie M. Walters, Asst. Atty. Gen., Lee A. Jackson and John M. Brant, Attys., Department of Justice, and Leigh B. Hanes, Jr., U. S. Atty., and James G. Welsh, Asst. U. S. Atty., on the brief), for appellees.

Before HAYNSWORTH, Chief Judge, and BRYAN and BUTZNER, Circuit Judges.


PER CURIAM:

From 1955 until the present controversy arose, the intervenor, Mrs. Couch, regularly delivered all of her financial books, records, and documents to her accountant, Mr. Shafer, so that he might compute and fill out her income tax returns. These records were thereafter stored by the accountant in his office. In 1969 an Internal Revenue agent investigating Mrs. Couch's returns for the years 1964 through 1968 requested, and was permitted to review those records...

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