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UNITED STATES v. LIEBMAN

No. 83-5766, 83-5842.

742 F.2d 807 (1984)

UNITED STATES of America and Clifton Beale, Revenue Agent, Internal Revenue Service v. Emanuel LIEBMAN and Liebman & Flaster, A Professional Law Corporation, Appellants.

United States Court of Appeals, Third Circuit.

Decided September 13, 1984.

Attorney(s) appearing for the Case

Herbert Odell, Robert D. Comfort (Argued), John P. Kopesky, Morgan, Lewis & Bockius, Philadelphia, Pa., for appellants.

W. Hunt Dumont, U.S. Atty., Newark, N.J., Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, Charles E. Brookhart, Gayle P. Miller (Argued), Tax Div., Dept. of Justice, Washington, D.C., for appellees.

Before GARTH and SLOVITER, Circuit Judges, and NEAHER, District Judge.

OPINION OF THE COURT

SLOVITER, Circuit Judge.

Emanuel Liebman and the law firm of Liebman & Flaster appeal from a district court order 569 F.Supp. 761 (D.N.J.1983) directing them to comply with an Internal Revenue Service summons. The appellants claim that enforcement of the summons, which seeks the names of all clients who paid fees over a three-year period in connection with the acquisition of certain tax shelters...

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