Is there any case law where a taxpayer can only claim privilege over records prepared by a third party?
MultiRegion, United States of America
The following excerpt is from U.S. v. Fox, 721 F.2d 32 (2nd Cir. 1983):
The district court, relying solely on our opinion on remand in United States v. Beattie, 522 F.2d 267 (2d Cir.1975), remanded, 425 U.S. 967, 96 S.Ct. 2163, 48 L.Ed.2d 791, modified on remand, 541 F.2d 329 (2 Cir.1976), ruled as a matter of law that the taxpayer could only claim the privilege with respect to records that he personally prepared. We disagree.
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