Ballas v. United States

T.G. NELSON, Circuit Judge:

I

OVERVIEW

George P. and Ann Balias, Samuel H. and Sara C. Booker, Robert J. David, Donald Housman, and Frank and Margaret W. Poor-man (“taxpayers”) appeal the district court’s order denying their petition for disclosure under Fed.R.Crim.P. 6(e) of grand jury investigative materials prepared by the Tax Division of the United States Department of Justice and the Internal Revenue Service during their investigation of the promoters of an abusive tax shelter called AMCOR. The district court concluded that the taxpayers-investors in AMCOR, who are currently petitioners for…