UNITED STATES v. ARTHUR YOUNG & CO.

No. 82-687.

465 U.S. 805 (1984)

UNITED STATES v. ARTHUR YOUNG & CO. ET AL.

Supreme Court of United States.

Decided March 21, 1984


Attorney(s) appearing for the Case

Mark I. Levy argued the cause for the United States. With him on the briefs were Solicitor General Lee, Assistant Attorney General Archer, Deputy Solicitor General Bator, Stuart A. Smith, Carleton D. Powell, and Kristina E. Harrigan.

Carl D. Liggio argued the cause for respondent Arthur Young & Co. With him on the brief were John E. Matson and Richard I. Janvey. William Eldred Jackson argued the cause for respondent Amerada Hess Corp. With him on the brief were Russell E. Brooks, John C. Maloney, Jr., and Robert G. Morvillo.*

Briefs of amici curiae urging affirmance were filed for the American Institute of Certified Public Accountants by Kenneth J. Bialkin and Louis A. Craco; for Arthur Andersen & Co. et al. by Eldon Olson, Victor M. Earle III, Donald Dreyfus, Harris J. Amhowitz, and Kenneth H. Lang; for the Committee on Corporate Law Departments of the Association of the Bar of the City of New York by David Lasky; and for the Tax Executives Institute, Inc., by Timothy J. McCormally.

Stephen A. Bokat filed a brief for the Chamber of Commerce of the United States as amicus curiae.


CHIEF JUSTICE BURGER delivered the opinion of the Court.

We granted certiorari to consider whether tax accrual workpapers prepared by a corporations independent certified public accountant in the course of regular financial audits are protected from disclosure in response to an Internal Revenue Service summons issued under § 7602 of the Internal Revenue Code of 1954 (Code), 26 U. S. C. § 7602.

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