Charles K. Chapman v. Norman Goodman, Special Agent of the Bureau of Internal Revenue

Norman Goodman, special agent of the Bureau of Internal Revenue, wants to conduct an examination of voluminous files and papers in the possession of Charles K. Chapman, a Long Beach attorney. He also desires that the attorney answer questions concerning the papers and certain transactions. All this is incident to an investigation of income tax liability of one Thomas A. Gregory, president of the Long Beach Federal Savings & Loan Association, who is a client of Chapman’s.

Essentially, this case began on October 20, 1952, when Goodman (now appellee) issued an administrative summons to Chapman (now appellant) to appear before him to testify and to bring papers “relating to financial transactions between Charles K. Chapman and Thomas A. Gregory.” Chapman responded to the subpoena and appeared. He brought no papers and he refused to be sworn. His appearance consisted of “standing on his rights.” He insisted that the information sought by Goodman was within the privilege ordinarily granted to lawyer and client.

Temporarily stymied, Goodman filed in the United States District Court for the Southern District of California a petition for an order to compel Chapman to attend and give…