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Kovel (D) was a former IRS agent who was employed by a law firm specializing in tax law. A grand jury was investigating tax violations by Hopps, a client of the law firm that D worked for. D was subpoenaed to appear, and the government was informed that D was an employee of the firm and could not reveal any work done for Hopps. D was convicted of contempt for refusing to answer. D appealed.

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