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RYAN v. UNITED STATES

No. 12.

379 U.S. 61 (1964)

85 S.Ct. 232

13 L.Ed.2d 122

RYAN v. UNITED STATES.

Supreme Court of United States.

Decided November 23, 1964.

Attorney(s) appearing for the Case

William R. Bagby argued the cause and filed briefs for petitioner.

Bruce J. Terris argued the cause for the United States. On the brief were Solicitor General Cox, Acting Assistant Attorney General Jones, Joseph M. Howard and Norman Sepenuk.

MR. JUSTICE HARLAN delivered the opinion of the Court.

In August 1961, Internal Revenue Agent Whelan issued a summons to taxpayer Ryan ordering him to produce his books for the years 1942 through 1953 inclusive. Ryan appeared but refused to produce the records, claiming that because tax liability for those years was long since barred except for fraud,1 the agent had no right to examine the records unless he could show grounds for suspecting...

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