In the 1983 case United States v. Arthur Young & Co., the U.S. Supreme Court ruled that accountants must provide tax accrual workpapers to the Internal Revenue Service (IRS) when requested during an audit, rejecting claims of accountant-client privilege. The court held that these documents were not protected by a confidentiality agreement between client and accountant because they are essential for accurate tax assessment and collection. This decision stemmed from a dispute where Arthur Young & Co., an accounting firm, refused to hand over certain papers related to its audits of Amerada Hess Corporation's federal income tax returns on grounds of confidentiality agreements with their clients. The ruling clarified that public interest in maintaining effective functioning of IRS outweighs any potential harm caused by disclosure.

In the dissenting opinion for United States v. Arthur Young & Co., Justice William Rehnquist argued that the majority's decision expanded the IRS's power beyond what Congress intended when it enacted § 7602 of the Internal Revenue Code. He contended that this section was meant to allow tax collectors access to relevant information, not to transform them into "auxiliary law enforcement agencies." Furthermore, he disagreed with the majority’s interpretation of “tax administration” as encompassing criminal investigations and prosecutions. Instead, he believed it should be limited to determining civil tax liability only. The justice also expressed concern about potential abuses of power by IRS agents if they were allowed such broad authority without any checks or balances in place.