United States v. Adlman
United States of America, Petitioner-Appellee,
Monroe Adlman, Respondent-Appellant.
68 F.3d 1495, 95-2 U.S.T.C.(CCH) P50,579; 76 A.F.T.R.2d (P-H) 7188 (2nd
PRIOR HISTORY: Appeal from an order entered in the United States District Court for the Southern District of New York, Whitman Knapp, Judge, enforcing an IRS summons to compel disclosure of memoranda prepared by Sequa Corporation's accountants. Appellants claim the protection of attorney-client privilege and the work product doctrine. We affirm the district court's finding that the attorney client privilege does not apply. As to work product, we reverse and remand for further findings.
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