LLOYD CORP., LTD.

v.

TANNER ET AL.

Citator

Cited By

• Couch v. United States, 409 U.S. 322 (U.S. 1973)
  …self-incrimination to prevent the production of her business and tax records in the possession of her accountant. [*324] Both the District Court3 and the Court of Appeals for the Fourth Circuit4 held the privilege unavailable. We granted certiorari, 405 U. S. 1038. Petitioner is the sole proprietress of a restaurant. Since 1955 she had given bank statements, payroll records, and reports of sales and expenditures to her accountant, Harold Shaffer, for the purpose of preparing her income tax returns. The accou…
• United States v. Gurtner, 474 F.2d 297 (9th Cir. 1973)
  …ns did not fall within the privilege. Such consultations, even with an attorney who is preparing the returns, are not privileged. Olender, supra, 210 F. 2d at 806; Canaday v. United States, 354 F. 2d 849, 857 (8th Cir. 1966); Couch v. United States, 405 U.S. 1038, 92 S.Ct. 1311, 31 L.Ed.2d 579 (1973). Even if there was an attorney-client relationship, Gurtner’s failure to make a timely objection to Foulk’s testimony constituted a waiver of the privilege. Gurtner failed to raise any objection to the testimon…
• United States v. Lorene Billingsley, 469 F.2d 1208 (10th Cir. 1972)
  …tum referred to the situation “where the sole object of the investigation is to gather data for criminal prosecution.” Donaldson v. United States, supra, at 533, 91 S.Ct. at 543; see United States v. Couch, 4 Cir., 449 F. 2d 141, 143, cert. granted, 405 U.S. 1038, 92 S.Ct. 1311, 31 L.Ed.2d 579. In the instant ease, as in all other tax fraud investigations, the potential for civil liability necessarily accompanied the potential for criminal prosecution. While a criminal investigation remains [*1210] solely w…

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