United States v. Walter C. Robson

How courts have described this case

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

• finding that the government can not “affirmatively mislead the taxpayer into believing that the investigation is exclusively civil in nature and will not lead to criminal charges”
• finding that revenue agent was not conducting covert criminal investigation because he had no instructions from CID, no interim conferences with CID personnel, and \was under no obligation to report to it unless his audit uncovered an indication of fraud\
• finding that revenue agent was not conducting covert criminal investigation because he had no instructions from CID, no interim conferences with CID personnel, and “was under no obligation to report to it unless his audit uncovered an indication of fraud”
• holding that the defendant’s consent to an IRS agent's search of records was not the product of deception where the IRS agent did not represent that the audit was only civil in nature and there was no evidence that IRS agent was asked about the scope of his investigation
• denying suppression where an IRS agent did not expressly advise a taxpayer that the evidence the agent was gathering for a civil audit would be used to support a criminal investigation
• denying suppression where an IRS agent did not expressly advise a taxpayer that the evidence the agent was gathering for a civil audit would be used to support a criminal investigation

Source: CourtListener parenthetical corpus (CC0).