United States v. Chevrontexoco Corp.

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• stating that when in-house attorneys wear “ ‘two hats,’ ” questions are raised about who the “ ‘client’ ” is in any particular communication
• noting that counsel provided legal 11 advice, assisted with implementation, and addressed legal issues that arose during 12 implementation
• finding that “[t]he mere fact” that counsel is copied 27 on an email “will not shield” communications that are not privileged
• explaining that in contrast to the “public watchdog” function of Arthur Young, “Price Waterhouse was not acting remotely as an independent auditor with respect to the challenged transaction”
• noting that a party fails to carry its burden 18 of demonstrating privilege where the document “does not contain or reveal a 19 communication between attorney and client”
• applying Kovel to find no privilege where accountant hired “to give additional legal advice about complying with the tax code”

Source: CourtListener parenthetical corpus (CC0).