The decedent (Mrs. Saunders) was the surviving spouse of a lawyer (Mr. Saunders) who represented a client who had a Swiss bank account. Mr. Saunders reported that fact to the IRS, apparently without the permission of and in violation of his duty to the client, a Mr. Stonehill. The client then suffered an investigation, the precise scope of which is not stated, but apparently involved the IRS, the FBI, the State Department and DOJ. Extensive tax litigation then resulted. In that litigation, the client was represented by another lawyer. In the litigation (which included FOIA litigation), the client's lawyer
obtained numerous previously classified documents from the Internal Revenue Service (IRS), Federal Bureau of Investigation, State Department, and Department of Justice. Among the documents Heggestad received during the FOIA litigation was an April 27, 1960, memorandum by IRS agent James H. Griffin (the Griffin memo). The Griffin memo suggested that Saunders had acted as a secret IRS informer against the interest of his client, Stonehill.