Legal Opinion
Gangi v. United States
District Court, D. Massachusetts
Decided March 4, 2014No. Civil Action Nos. 14-10114-DPW, 14-10115-DPW, 14-10116-DPW, 14-10117-DPWPublishedCited by 3 opinions
1Opinion of the Court
MEMORANDUM AND ORDER
DOUGLAS P. WOODLOCK, District Judge.
The Internal Revenue Service is engaged in an investigation to determine whether Frank Gangi, one of the petitioners before me, owes federal income tax liability for the years 2000 through 2004. As part of that investigation, the IRS has issued four summonses to third parties located in Massachusetts.
*15The petitioners have filed petitions seeking to quash each of these summonses, contending, among other things, that the IRS’s investigation is being conducted for an improper purpose and in bad faith. I reject the petitioners’ contentions…
2Cases cited14 opinions
- United States v. PowellSupreme Court of the United States · 1964
- United States v. RicheyCourt of Appeals for the Ninth Circuit · 2011
- United States v. Nancy Gertner, Etc., John Doe, IntervenorCourt of Appeals for the First Circuit · 1995
- Manganella v. Evanston Insurance CompanyCourt of Appeals for the First Circuit · 2012
- United States of America v. Lawn Builders of New England, Inc., and James T. Shadoian, United States of America v. James T. ShadoianCourt of Appeals for the First Circuit · 1988
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3Cited by3 opinions
- High Desert Relief, Inc. v. United StatesCourt of Appeals for the Tenth Circuit · 2019
- J.B. v. United StatesCourt of Appeals for the Ninth Circuit · 2019
- Highland Capital Management, L.P. v. United StatesDistrict Court, S.D. New York · 2014