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U.S. v. ZHONG H. CHEN

No. 14-2003.

815 F.3d 72 (2016)

UNITED STATES of America, Petitioner, Appellee, v. ZHONG H. CHEN, Respondent, Appellant.

United States Court of Appeals, First Circuit.

February 29, 2016.

Attorney(s) appearing for the Case

William J. Lovett , with whom Melissa S. Baldwin and Collora LLP were on brief, for appellant.

Alexander P. Robbins , Attorney, Tax Division, Department of Justice, with whom Robert J. Branman , Attorney, Tax Division, Department of Justice, Caroline D. Ciraolo , Acting Assistant Attorney General, Diana L. Erbsen , Deputy Assistant Attorney General, Gilbert S. Rothenberg , Robert W. Metzler , Attorneys, Tax Division, Department of Justice, and Carmen M. Ortiz , United States Attorney, were on brief, for appellee.

Before LYNCH, Circuit Judge, SOUTER, Associate Justice, and STAHL, Circuit Judge.

Tensions between taxpayers and the Internal Revenue Service ("IRS") over forced disclosure of foreign bank account information implicate both statutory and constitutional rights. Taxpayers have Fifth Amendment rights not to be forced to incriminate themselves by the compelled act of production. But where the documents are required...

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