Does the fifth amendment protect records of a post-incorporation law firm?

Turning to Doe's fifth amendment argument, it is well settled that the amendment does not protect the subpoenaed records of the post-incorporation law firm. No artificial organization may invoke the personal privilege against self-incrimination. See Bellis v. United States, 417 U.S. 85, 90, 94 S.Ct. 2179, 2184, 40 L.Ed.2d 678 (1974). As to the pre-incorporation firm, we agree with the government that it should be treated as a "collective entity", not as a solo practice, and that Doe's personal privilege against self-incrimination is therefore inapplicable. ² See Bellis, supra.