United States v. Chen

MEMORANDUM & ORDER

YOUNG, District Judge.

I. INTRODUCTION

The United States of America (the “United States”) brings this petition on behalf of the Internal Revenue Service (the “IRS”) to enforce an administrative summons served by the IRS on Zhong H. Chen (“Chen”) pursuant to 26 U.S.C. section 7604(a). Pet. Enforce IRS Summons (“IRS Pet.”) ¶ 1, ECF No. 1. In support of its summons, the IRS alleges that its request for documents is necessary in order that it may “examine the summonsed records to properly determine the federal tax liabilities of Chu H. Ng and Zhong H. Chen for the taxable period…