The document is a summary of the U.S. Supreme Court case United States v. Zolin, which dealt with the IRS's attempt to access documents related to L. Ron Hubbard's tax returns. The case focused on whether the IRS could enforce a summons for documents that included privileged attorney-client communications, and whether the crime-fraud exception to the privilege applied. The Court held that in camera review could be used to determine the applicability of the crime-fraud exception, but required a threshold showing of evidence before such a review could be conducted.
documents/EFTA00749279.pdf
{}