United States v. Bernhoft

DECISION AND ORDER

RUDOLPH T. RANDA, District Judge.

BACKGROUND

On June 13, 2008, the Petitioner, the United States of America (“the Government”), filed a petition to enforce an Internal Revenue Service (“IRS”) administrative summons against the Respondent, Robert Bernhoft (“Bernhoft”). The summons was issued pursuant to 26 U.S.C. § 7602 in connection with an IRS investigation into whether Joseph Banister (“Banister”) — an independent contractor of Bernhoft’s law firm, Bernhoft Law Firm, S.C. (the “Law Firm”) — is engaging in the promotion of abusive tax schemes such as tax shelters that would…