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Estate Trust, for which petitioners were appointed general
managers and managing agents and, as such, had the same duties
and responsibilities as the respective trustees of the trusts.
That distinction is critical as far as the Supreme Court is
concerned. In United States v. White, 322 U.S. 694 (1944), the
Supreme Court distinguished Boyd v. United States, supra, in
cases where, as here, the requested documents are not those
belonging to the individual personally but are those that the
individual holds in his or her capacity as a representative of a
so-called collective entity. The Supreme Court stated: “indi-
viduals, when acting as representatives of a collective group,
cannot be said to be exercising their personal rights and duties
nor to be entitled to their purely personal privileges.” Id. at
699 (distinguishing Boyd v. United States, supra). On the
instant record, we find that petitioners, as the appointed
general managers and managing agents of both Sandbar Wholesale
Trust and Sandbar Real Estate Trust, have no valid claims under
the Fourth Amendment that would prevent production of the re-
quested trust documents.7
7Nor would we find on the instant record that petitioners
have a valid claim under the Fourth Amendment assuming arguendo
that the requested trust documents were petitioners’ private
documents, rather than trust documents. “Requiring taxpayers,
who institute civil proceedings protesting deficiency notices, to
produce records or face dismissal constitutes no invasion of
privacy or unlawful search or seizure.” Edwards v. Commissioner,
680 F.2d 1268, 1270 (9th Cir. 1982), affg. per curiam an order of
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