United States v. Sideman & Bancroft, LLP

OPINION

WALLACE, Circuit Judge:

Sideman & Bancroft, LLP (Sideman) appeals from the district court’s order enforcing an Internal Revenue Service (IRS) administrative summons. We have jurisdiction under 28 U.S.C. § 1291, and we affirm.

I

The IRS is currently undertaking a criminal investigation of Mary Nolan to determine whether she attempted to evade or defeat her tax liabilities or made a false declaration under penalty of perjury related to tax years 2005 to 2008. As part of that investigation, the IRS obtained a search warrant to locate Nolan’s tax documents for those years. On October 13,…