This section contains the nature of the case and procedural background.

These cases involve the validity of two civil investigative summonses issued by the Internal Revenue Service (IRS). The IRS began a formal tax investigation of Howard. Howard was arrested on a drug charge. Contraband and documents had been seized in a search of Howard's residence under a search warrant. The IRS got copies of all the documents. The IRS then issued summonses to the taxpayer's attorneys and accountants. D, an attorney, and a certified public accountant, had prepared Howard's tax returns for several of the years in question. The summons required Ds to produce and testify as to two categories of documents. D was to bring all records in his possession of financial transactions by Howard or corporations in which Howard had participated for the years 1974 through 1978. D was to produce the workpapers he had generated in the course of preparing Howard's tax returns for those years. D refused to comply with any part of the summons, citing the attorney-client privilege. P filed a petition to enforce the summons. Ds made blanket assertions concerning the attorney-client privilege, the work product doctrine, and their client's fifth amendment privilege, all of which the district court rejected. The district court issued an order granting P's petition in full. D and his law partner, Orr, who had also been served a summons appealed.

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