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UNITED STATES v. RICHARDS

Nos. 80-1023, 80-1084.

631 F.2d 341 (1980)

UNITED STATES of America; P. L. Sylvia, Jr., Revenue Agent, Internal Revenue Service, Appellants, v. Harold J. RICHARDS, Appellee. UNITED STATES of America; P. L. Sylvia, Jr., Revenue Agent, Internal Revenue Service, Appellees, v. Harold J. RICHARDS, Appellant.

United States Court of Appeals, Fourth Circuit.

Decided October 2, 1980.

Attorney(s) appearing for the Case

William A. Whitledge, Tax Div., Dept. of Justice, Washington, D.C. (Justin W. Williams, U. S. Atty., M. Carr Ferguson, Asst. Atty. Gen., Gilbert E. Andrews, Carleton D. Powell, Tax Div., Dept. of Justice, Washington, D.C., on brief), for appellants/cross-appellees.

Robert J. Jones, Washington, D.C. (Milton V. Freeman, Walter J. Rockler, Stephen L. Hester, Thomas D. Fuller, Arnold & Porter, Washington, D.C., on brief), for appellee/cross-appellant.

Before FIELD, Senior Circuit Judge, and HALL and SPROUSE, Circuit Judges.

FIELD, Senior Circuit Judge:

Incident to an investigation of the federal income tax liability of Fidelity Corporation for the years 1971-1974, P. L. Sylvia, an Internal Revenue Agent, issued a summons to Harold J. Richards, president of the corporation during the years in question, directing him to appear and respond to a series of eleven questions.1 The questions were part of the Service's Coordinated...

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