Tax briefs: Summonses
An individual’s motion to dismiss the government’s action for enforcement of IRS summonses seeking his documents and testimony on the ground that a Tax Court ruling never became a final and appealable order was rejected; the evidence established that he had been served with a copy of the court’s order and that he failed to timely file a notice of appeal. Moreover, he was served with a copy of the IRS’s computation for that case.
Cleveland, DC I11., 94-2 USTC para 150,421
Absent a showing that its investigation was a sham, the government was not required to comply with “John Doe” procedures as a prerequisite for obtaining enforcement of summonses issued to an attorney seeking the identity of clients who had made cash payments exceeding $10,000. Further, disclosure of the names, addresses, and taxpayer identification numbers of the clients did not violate the attorney-client privilege.
Sepenuk, DC Ore., 94-2 USTC para 50,422
Copyright Commerce Clearing House, Inc. Sep 1, 1994
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