Nature of the Case
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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.
Holding and Decision
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Legal Analysis
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