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D, an attorney, was retained by the co-executors of the estate to prepare the federal estate tax return of Edna E. Dieken, deceased. Summonses were issued to D to testify regarding the tax return and to produce the following documents: All books, papers, records, and other documents in your possession or control relating to the preparation or audit of the United States Estate Tax Return, Form 706, for EDNA E. DIEKEN. D refused to comply with the summonses and enforcement proceedings were commenced. D resisted the summonses upon the basis of attorney-client privilege. After an in camera examination of the six documents in dispute, the district court concluded that four of them were not privileged. With respect to documents 18 and 19, the district court ruled they were privileged. P objected to the ruling, arguing that D had made no showing that these documents were intended to be confidential, and that, from the description of the documents, they were intended for use in the preparation of the tax return. P appealed.

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