“[D]efendant Galloway moves to suppress from admission into evidence the tax records received from CPA Livsey by IRS agents, arguing that 26 U.S.C. § 7609 and the Code of Professional Conduct for CPA’s conferred upon him a reasonable expectation of privacy in the documents he had provided to his accountant, Livsey. (Doc. No. 67 at 6-7.) Alternatively, defendant Galloway argues the court should exercise its equitable powers to exclude from evidence at trial the business records that the government obtained due to the failure to comply with the requirements of 26 U.S.C. §§ 7603 and 7609. (Id. at 11.)” Valiant try but rejected. “Fatal to this aspect of the pending motion is the fact that defendant Galloway had no legitimate expectation of privacy in the tax records he had turned over to his accountant. Generally speaking, one does not have a reasonable expectation of privacy in information revealed to a third party which is passed on to the government.” Couch and the third-party doctrine require rejection of the argument. United States v. Galloway, 2017 U.S. Dist. LEXIS 26362 (E.D. Cal. Feb. 23, 2017):
Most importantly for resolution of the pending motion, it is well established that a person has no expectation of privacy in business and tax records turned over to an accountant. Couch v. United States, 409 U.S. 322, 335-36, 93 S. Ct. 611, 34 L. Ed. 2d 548 (1973). In Couch, a taxpayer hired an accountant as an independent contractor and for many years delivered her business records to him for purposes of preparing her taxes. 409 U.S. at 324. The IRS undertook an investigation of the taxpayer for tax fraud in connection with the underreporting of her income. Id. As part of that investigation the IRS issued a summons to the accountant for the taxpayer’s records. Id. at 325. The taxpayer asserted ownership of the business records and asserted a Fifth Amendment privilege as well as a reasonable expectation of privacy in them under the Fourth Amendment in an attempt to thwart their production. Id. at 325, 335. The Supreme Court rejected these claims, reasoning as follows: …
The holding in Couch has been consistently applied by the lower federal courts. See United States v. Hickok, 481 F.2d 377, 379 (9th Cir. 1973); KRL v. Moore, No. 2:99-cv-02437-JAM-DAD, 2006 U.S. Dist. LEXIS 8314, 2006 WL 548520, at *4 (E.D. Cal. Mar. 3, 2006) (“It is well established that a person has no expectation of privacy in business and tax records turned over to an accountant.”), aff’d in part, rev’d in part on other grounds, and remanded sub nom. KRL v. Estate of Moore, 512 F.3d 1184 (9th Cir. 2013); United States v. McLaughlin, 910 F. Supp. 1054, 1059 (E.D. Pa. 1995) (“Moreover, the defendants’ voluntary provision of the records to [his accountant] knowing that they would be used to prepare and be incorporated into tax returns which would be viewed by others, establishes that the defendants had no legitimate expectation of privacy in them.”). Couch and its progeny control here, especially in light of the fact that is undisputed that defendant Galloway provided his records to CPA Livsey with the understanding that they would be turned over in the course of the IRS tax audit.
Contrary to defendant’s assertion, the enactment of 26 U.S.C. § 7609 did not alter this well-established principal. At the outset, it must be recognized that Congress gave the IRS a “broad mandate to investigate and audit persons who may be liable for taxes.” United States v. Bisceglia, 420 U.S. 141, 145, 95 S. Ct. 915, 43 L. Ed. 2d 88 (1975) (internal quotation marks omitted). In order to assist the IRS in carrying out that mandate, it was provided the authority to “summon the person liable for tax … or any other person … to appear before the Secretary … and to produce … books, papers, records, or other data.” 26 U.S.C. § 7602(a)(2). Section 7609 of Title 26 merely provides that when an IRS summons is served on a “third-party record keeper,” the taxpayer to whom the records named in the summons relate is entitled to notice of the summons, and may move to quash the summons or intervene in the summons enforcement proceeding. 26 U.S.C. §§ 7609(a) and (b). According to the Congressional Committee Report, the purpose of § 7609, is merely to facilitate a taxpayer’s opportunity to raise defenses to a third party summons.
Congress enacted § 7609 in response to the Supreme Court’s decisions in Donaldson v. United States, 400 U.S. 517, 91 S. Ct. 534, 27 L. Ed. 2d 580 (1971) and United States v. Bisceglia, 420 U.S. 141, 95 S. Ct. 915, 43 L. Ed. 2d 88 (1975). See Tiffany Fine Arts, Inc. v. United States, 469 U.S. 310, 314-15, 105 S. Ct. 725, 83 L. Ed. 2d 678 (1985). In Donaldson the Supreme Court had affirmed the denial of an employee’s motions for intervention to oppose the enforcement of an IRS summons issued to his employer. 469 U.S. at 315. In Bisceglia the Supreme Court had upheld a third party summons issued by the IRS to a bank for purposes of identifying an unnamed individual who had deposited a large amount of severely deteriorated currency with the bank. Id. In response, citing only those two decisions in reports, in 1976 Congress enacted § 7609 addressing third party summons served by the IRS to ensure that: (1) the taxpayer to whose business or transactions the summoned records related is informed of the summons and provided an opportunity to intervene in any enforcement proceedings; and (2) in the case of so-called “John Doe” summons where the identity of the specific taxpayer is not known, the government makes a required showing in a court proceeding prior to issuance of the summons. Id. at 315-17.
"If it was easy, everybody would be doing it. It isn't, and they don't." —Me
"Life is not a matter of holding good cards, but of playing a poor hand well." –Josh Billings (pseudonym of Henry Wheeler Shaw), Josh Billings on Ice, and Other Things (1868) (erroneously attributed to Robert Louis Stevenson, among others)
“I am still learning.” —Domenico Giuntalodi (but misattributed to Michelangelo Buonarroti (common phrase throughout 1500's)).
"Love work; hate mastery over others; and avoid intimacy with the government."
—Shemaya, in the Thalmud
"It is a pleasant world we live in, sir, a very pleasant world. There are bad people in it, Mr. Richard, but if there were no bad people, there would be no good lawyers."
—Charles Dickens, “The Old Curiosity Shop ... With a Frontispiece. From a Painting by Geo. Cattermole, Etc.” 255 (1848)
"A system of law that not only makes certain conduct criminal, but also lays down rules for the conduct of the authorities, often becomes complex in its application to individual cases, and will from time to time produce imperfect results, especially if one's attention is confined to the particular case at bar. Some criminals do go free because of the necessity of keeping government and its servants in their place. That is one of the costs of having and enforcing a Bill of Rights. This country is built on the assumption that the cost is worth paying, and that in the long run we are all both freer and safer if the Constitution is strictly enforced."
—Williams
v. Nix, 700 F. 2d 1164, 1173 (8th Cir. 1983) (Richard Sheppard Arnold,
J.), rev'd Nix v. Williams, 467 US. 431 (1984).
"The criminal goes free, if he must, but it is the law that sets him free. Nothing can destroy a government more quickly than its failure to observe its own laws,
or worse, its disregard of the charter of its own existence." —Mapp
v. Ohio, 367 U.S. 643, 659 (1961).
"Any costs the exclusionary rule are costs imposed directly by the Fourth Amendment."
—Yale Kamisar, 86 Mich.L.Rev. 1, 36 n. 151 (1987).
"There have been powerful hydraulic pressures throughout our history that
bear heavily on the Court to water down constitutional guarantees and give the
police the upper hand. That hydraulic pressure has probably never been greater
than it is today."
— Terry
v. Ohio, 392 U.S. 1, 39 (1968) (Douglas, J., dissenting).
"The great end, for which men entered into society, was to secure their
property."
—Entick
v. Carrington, 19 How.St.Tr. 1029, 1066, 95 Eng. Rep. 807 (C.P. 1765)
"It is a fair summary of history to say that the safeguards of liberty have
frequently been forged in controversies involving not very nice people. And
so, while we are concerned here with a shabby defrauder, we must deal with his
case in the context of what are really the great themes expressed by the Fourth
Amendment."
—United
States v. Rabinowitz, 339 U.S. 56, 69 (1950) (Frankfurter, J., dissenting)
"The course of true law pertaining to searches and seizures, as enunciated
here, has not–to put it mildly–run smooth."
—Chapman
v. United States, 365 U.S. 610, 618 (1961) (Frankfurter, J., concurring).
"A search is a search, even if it happens to disclose nothing but the
bottom of a turntable."
—Arizona
v. Hicks, 480 U.S. 321, 325 (1987)
"For the Fourth Amendment protects people, not places. What a person knowingly
exposes to the public, even in his own home or office, is not a subject of Fourth
Amendment protection. ... But what he seeks to preserve as private, even in
an area accessible to the public, may be constitutionally protected."
—Katz
v. United States, 389 U.S. 347, 351 (1967)
“Experience should teach us to be most on guard to
protect liberty when the Government’s purposes are beneficent. Men born
to freedom are naturally alert to repel invasion of their liberty by evil-minded
rulers. The greatest dangers to liberty lurk in insidious encroachment by men
of zeal, well-meaning but without understanding.”
—United
States v. Olmstead, 277 U.S. 438, 479 (1925) (Brandeis, J., dissenting)
“Liberty—the freedom from unwarranted intrusion by government—is as easily lost through insistent nibbles by government officials who seek to do their jobs too well as by those whose purpose it is to oppress; the piranha can be as deadly as the shark.”
"You can't always get what you want / But if you try sometimes / You just might find / You get what you need." —Mick Jagger & Keith Richards, Let it Bleed (album, 1969)
"In Germany, they first came for the communists,
and I didn't speak up because I wasn't a communist. Then they came for the Jews,
and I didn't speak up because I wasn't a Jew. Then they came for the trade unionists,
and I didn't speak up because I wasn't a trade unionist. Then they came for
the Catholics and I didn't speak up because I wasn't a Catholic. Then they came
for me–and by that time there was nobody left to speak up."
—Martin Niemöller (1945) [he served seven years in a concentration
camp]
“Children grow up thinking the adult world is ordered, rational, fit for purpose. It’s crap. Becoming a man is realising that it’s all rotten. Realising how to celebrate that rottenness, that’s freedom.” – John le Carré, The Night Manager (1993), line by Richard Roper
"The point of the Fourth Amendment, which often is not grasped by zealous officers, is not that it denies law enforcement the support of the usual inferences which reasonable men draw from evidence. Its protection consists in requiring that those inferences be drawn by a neutral and detached magistrate instead of being judged by the officer engaged in the often competitive enterprise of ferreting out crime." —Johnson v. United States, 333 U.S. 10, 13-14 (1948)
The book was dedicated in the first (1982) and sixth (2025) editions to Justin William Hall (1975-2025). He was three when this project started in 1978.