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HODGES, GRANT & KAUFMANN v. U.S. GOVERNMENT

No. 84-1682.

762 F.2d 1299 (1985)

HODGES, GRANT & KAUFMANN and Tom Harrell, Inc., Plaintiffs-Appellants, Cross-Appellees, v. UNITED STATES GOVERNMENT, DEPARTMENT OF the TREASURY, INTERNAL REVENUE SERVICE, Defendant-Appellee, Cross-Appellant.

United States Court of Appeals, Fifth Circuit.

June 17, 1985.

Attorney(s) appearing for the Case

Hiram C. Eastland, Jr., Jackson, Miss., for plaintiffs-appellants, cross-appellees.

Joanne E. Nitzberg, Jackson, Miss., for Jones.

Glenn L. Archer, Jr., Asst. Atty. Gen., U.S. Dept. of Justice, Tax. Div., Michael L. Paup, Chief, Appellate Div., Charles E. Brookhart, William A. Whitledge, Washington, D.C., for defendant-appellee, cross-appellant.

Before RUBIN, WILLIAMS, and DAVIS, Circuit Judges.

ALVIN B. RUBIN, Circuit Judge:

The Internal Revenue Service issued a summons commanding an accountant to produce records pertaining to a taxpayer's business. The accountant and the taxpayer's law firm which had hired him resisted production, and the taxpayer appeared at the proceedings, but refrained from intervening in them, as he had a statutory right to do, presumably because intervention would toll the statute of limitations on assessment of any tax deficiency...

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