United States v. Berg

Taxpayers, Phillip and Susan Fry and eight entities,1 appeal from two orders of the district court granting the government’s petition for enforcement of two summonses issued to the respondent banking institutions by the Internal Revenue Service. After careful review of the entire file, counsel’s briefs and oral argument, we determine that the orders of the district court should be affirmed.

The court below correctly determined that the government’s burden was met upon the showing that the investigation was conducted for a legitimate purpose; that the information sought by the I.R.S. was not…