United States v. Baggot
Decided June 30, 1983. William Joseph Brennan Jr. delivered the opinion of the Court.
Docket 81-1938 · 463 U.S. 476 (1983) · Cited 208 times
Holding
The IRS's civil tax audit is not "preliminar to or in connection with a judicial proceeding" within the meaning of Rule 6(e)(3)(C)(i), and hence no disclosure is available under that Rule.
The Court’s statement of the holding, from the opinion’s syllabus. The syllabus is prepared by the Reporter of Decisions and is not part of the opinion of the Court — read the official opinion for authority.
How the Justices voted
Decided 8–1.
Majority · 8
Dissenting · 1
- Warren Earl Burger · filed a dissenting opinion
“Concurring” means agreeing with the outcome; any split shown is the Court’s judgment, not each Justice’s reasoning. Source: the Supreme Court Database (Spaeth et al.), Washington University.
Precedents cited
Supreme Court decisions this opinion relies on, ordered by how often it cites each. Cases in our collection link through; others are named.
- Douglas Oil Co. of Cal. v. Petrol Stops Northwest · 441 U.S. 211 (1979)
- United States v. Procter & Gamble Co. · 356 U.S. 677 (1958)
Official text
Read the official opinion (U.S. Reports, govinfo.gov)
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William Joseph Brennan Jr.’s profile · All Supreme Court opinions · The Supreme Court
Source: Supreme Court of the United States, slip opinions (1983). Citation count from the Free Law Project’s CourtListener bulk data. Data last verified 2026-07-03. Informational only; verify against the primary source before relying. Not a consumer report (FCRA).