An attorney (Kenneth Reiserer) who sold patently abusive offshore employee leasing tax avoidance schemes. An IRS subpoena on the attorney's account at Bank of America. A motion to quash. A dead attorney. A claim of privilege. Imposition of tax penalties on the dead attorney. An appeal.
Judge Schwarzer (sitting by designation) has the rest of the story. Affirmed.
P.S. - A little digging reveals that Mr. Reiserer (who practiced in California and then moved to Washington State in 1997) apparently fought in Vietnam and was awarded the Bronze Star. Too bad his final recognition arises from pitching abusive shelters.