Nash v. Farmers New World Life Insurance

How later courts describe this case

• “proceeding” generally applies to investigation prior to a trial or to adjudicative functions of a department or agency
• taxpayer challenging agency investigatory action must make substantial preliminary showing of improper purpose on part of agency before even limited discovery need be ordered
• fact that false statements procured by the defendant were made during the course of an “investigation or the search for the true facts” did not render it a “non-proceeding”
• DEA agents contracted with defendants for the importation of cocaine