United States v. Moon

This is an appeal from five orders of the district court1 enforcing five Internal Revenue summonses. For the reasons discussed below, we affirm.

The facts leading to this appeal are not in dispute and may be summarized as follows:

Patrick J. Finnessey is a Special Agent of the Internal Revenue Service. As part,of his duties, Special Agent Finnessey was assigned to conduct an investigation into the income tax liability of Dr. Paul A. Hein, Jr. (intervenor below, appellant in the present appeal) for the years 1976 and 1977. As part of that investigation, Special Agent Finnessey issued Internal…