An Emerging Trend in Summons Proceedings?

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This paper looks at what appears to be an emerging trend in tax summons enforcement: that district courts actually review documents for which the summoned party claims a privilege. In December 2017 the Ninth Circuit seemingly joined the Second Circuit and the D.C. Circuit in finding that a district court's failure to review documents in camera was an abuse of discretion. <br><br>These holding appear to contradict Supreme Court guidance. The paper reviews summons enforcement proceedings and gives a critical analysis of the in camera review requirement as potentially inconsistent with Supreme Court's holding in Zolin.
Original languageEnglish
Pages (from-to)1201-1206
JournalTax Notes
StatePublished - Feb 26 2018


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