In the 1972 case Couch v. United States, the Supreme Court ruled that a taxpayer does not have the right to prevent Internal Revenue Service (IRS) agents from seizing their tax records in possession of an accountant. The court held that there is no reasonable expectation of privacy for these documents under Fourth Amendment protections against unreasonable searches and seizures because they are business records often shared with others. The court also noted that since accountants are independent contractors rather than employees, clients do not have control over how they handle or store such documents. Therefore, taxpayers cannot claim Fifth Amendment protection against self-incrimination as it pertains to these papers either.

In the dissenting opinion for Couch v. United States, Justice William O. Douglas argued that a taxpayer has a Fifth Amendment privilege to prevent their accountant from submitting tax records to the government without consent. He contended that this case was not about whether an individual can avoid paying taxes or hide fraudulent activities, but rather it was about protecting citizens' right against self-incrimination under the Constitution's Fifth Amendment. The majority decision held that there is no ownership in information and therefore no privacy interest protected by the Fourth Amendment; however, Douglas disagreed with this view as he believed it undermined individuals' constitutional rights and protections against unreasonable searches and seizures.