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UNITED STATES v. BAGGOT

No. 81-1938.

463 U.S. 476 (1983)

103 S.Ct. 3164

77 L.Ed.2d 785

UNITED STATES v. BAGGOT

Supreme Court of United States.

Decided June 30, 1983

Attorney(s) appearing for the Case

Deputy Solicitor General Wallace argued the cause for the United States. With him on the briefs were Solicitor General Lee, Assistant Attorney General Archer, Harriet S. Shapiro, Robert E. Lindsay, and William A. Whitledge.

Samuel J. Betar argued the cause and filed a brief for respondent.*

JUSTICE BRENNAN delivered the opinion of the Court.

In United States v. Sells Engineering, Inc., ante, p. 418, we decide today that in some circumstances the Government may obtain disclosure of grand jury materials for civil uses under Federal Rule of Criminal Procedure 6(e)(3)(C)(i) (hereinafter sometimes referred to as (C)(i)). The question in this case is whether an Internal Revenue Service investigation to determine a taxpayer's civil tax liability...

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