United States of America and Thornton J. Camfield, Special Agent, Internal Revenue Service v. Wall Corporation

The questions presented by this appeal are whether an Internal Revenue Service summons, issued pursuant to 26 U.S.C. § 7602, requiring Wall Corporation to produce books, records, expense vouchers and other data relevant to the tax liability of Daniel C. and Roslyn Wall was issued for a proper purpose, and whether the District Court erred in refusing to permit Wall Corporation discovery designed to adduce the purpose of the summons. After careful consideration of Donaldson v. United States, 400 U.S. 517, 91 S.Ct. 534, 27 L.Ed.2d 580 (1970), and post-Donaldsow cases, 1 we affirm the District…