The following excerpt is from U.S. v. Popkin, 623 F.2d 108 (9th Cir. 1980):
Although a routine audit had previously been conducted by a revenue agent, such a routine audit does not fulfill the needs of a special agent investigating fraud. United States v. Lenon, 579 F.2d 420, 422 (7th Cir. 1978). Therefore the government is not deemed to be in possession of the information. Id.
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