Does an individual retain his Fifth Amendment privilege in the face of the 'foregone conclusion doctrine' when an IRS summons requires him, in effect, to provide testimony (akin to responses to interrogatories)?

QUESTIONS PRESENTED 1. Does an individual retain his Fifth Amendment privilege in the face of the “foregone conclusion doctrine” when an IRS summons requires him, in effect, to provide testimony (akin to responses to interrogatories)? 2. Does an individual retain his Fifth Amendment privilege in the face of the “collective entity doctrine” when an IRS summons issued to him in his personal capacity seeks to compel production of documents of a corporation, but there is no evidence or no finding of fact that he is a custodian of the corporate records? 3. Can the Government compel an individual who asserts his Fifth Amendment privilege to disclose whether he is a custodian of records of a collective entity and then, in reliance on that compelled disclosure, demand that he produce the entity’s records? i RELATED CASES United States v. Fridman, No. 15-mc-64, U.S. District Court for the Southern District of New York. Judgment entered on November 25, 2015, and on November 14, 2018. United States v. Fridman, No. 15-3969-cv, U.S. Court of Appeals for the Second Circuit. Judgment entered on December 13, 2016. United States v. Fridman, No. 18-3530-cv, U.S. Court of Appeals for the Second Circuit. Judgment entered on September 9, 2020. ii