In a constitutional challenge to federal tax requirement powers, legal professional secrecy was weighed against the state’s audit and collection objectives.
The court held that compelling production from legal advisers without adequate notice to clients, without judicially supervised safeguards, and with an overbroad accounting-records exception produced unreasonable seizures under s. 8.
The impugned provisions failed minimal impairment and were not justified under s. 1.
The provisions were read down to exclude notaries and lawyers acting as legal advisers, and the accounting-records exception was declared invalid.
