Scotty's Contracting and Stone, Inc. v. United States

OPINION

GIBBONS, Circuit Judge.

The appellant, Scotty’s Contracting & Stone Company (Scotty’s), filed this action seeking to quash two third-party summonses issued by the Internal Revenue Service to Scotty’s accountants. The district court denied Scotty’s petition to quash and granted the government’s motion for summary enforcement of the summonses. Scotty’s appeals. For the following reasons, we affirm.

In 1998, the IRS initiated an investigation into the federal tax liabilities of James Scott for the years 1994, 1995 and 1996. Scott, a resident of Kentucky, is the owner and operator of…