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

The McCues retained a law firm (SWP), who hired Schmidt (D), an accountant. D and SWP entered an agreement. This agreement stated that all of D's services were to be performed at the written request of SWP, that the McCues were SWP's clients, and that D was required to give accurate and complete legal advice and consultation. SWP was given all of D's work product as its exclusive property. Any information obtained by D was to be considered confidential. The Internal Revenue Service issued a summons requiring D to testify as to the McCues' tax liability. D claimed the attorney-client privilege and refused to answer questions. The IRS then sought judicial enforcement of the summons.

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