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IN RE GRAND JURY SUBPOENA

Nos. 89-5619, 89-5632 through 89-5634.

920 F.2d 235 (1990)

In re GRAND JURY SUBPOENA. (Four Cases) UNITED STATES of America, Plaintiff-Appellee, v. UNDER SEAL, Defendant-Appellant. (Four Cases)

United States Court of Appeals, Fourth Circuit.

Decided December 6, 1990.

Attorney(s) appearing for the Case

James Allen Rothschild, Anderson, Coe & King, Baltimore (James P. Ulwick, Kramon & Graham, P.A., Baltimore, on brief), for defendant-appellant.

Martin Stanley Himeles, Jr., Asst. U.S. Atty., Baltimore (Breckinridge L. Willcox, U.S. Atty., Baltimore, on brief) for plaintiff-appellee.

Before SPROUSE and CHAPMAN, Circuit Judges, and WARD, Senior United States District Judge for the Middle District of North Carolina, sitting by designation.

SPROUSE, Circuit Judge:

This appeal concerns information developed by a tax fraud investigation initiated by the Internal Revenue Service (IRS) and pursued by both the IRS and a federal grand jury. The investigation targeted appellants — a parent corporation, its subsidiaries, and several individual employees of the corporations. Records of two of the corporations were seized by IRS agents pursuant to search warrants and records of the other corporations by...

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