Paine v. U.S. Government

MEMORANDUM AND ORDER

WEXLER, District Judge.

Petitioners Lloyd N. Paine III (“Paine”) and Bernd Hoffman, a.k.a. Phillip B. Paine (collectively the “taxpayers”) commenced this proceeding pursuant to 26 U.S.C. § 7609(b)(2)(A) to quash two Internal Revenue Service summonses (the “Summonses”) issued by the United States to third-party record keepers in possession of certain of Paine’s bank records. In response, the United States has moved, pursuant to the above-referenced statute, to compel compliance with the Summonses. For the reasons set forth below, the petitioners’ motion to quash is denied…