Couch v. United State

409 U.S. 322 (1973)

Facts

Couch (D) gave her tax records to an independent accountant for a period of years. The Internal Revenue Service issued a summons to the accountant, ordering production of the records due to a tax fraud question. D learned of this summons and had the accountant give these records to her attorney. She then refused to produce the records, disobeying the summons.