In Couch v. United States, 409 U.S. 322, 324, 34 L. Ed. 2d 548, 93 S. Ct. 611 (1973), the Court decided the "question . . . whether the taxpayer may invoke her Fifth Amendment privilege against compulsory self-incrimination to prevent the production of her business and tax records in the possession of her accountant." The Court held that when an individual surrenders his or her business records to the possession of a third party, and the government subpoenas the third party to produce the records, the individual has no expectation of privacy in the records and the Fifth Amendment does not bar their production. See 409 U.S. at 329-330. Significantly, the Court noted that Boyd concerned an accused who possessed his own private papers and "did not . . . address or contemplate the divergence of ownership and possession." Id. at 330.