United States v. Schneider

MEMORANDUM AND ORDER

ALLEN SHARP, District Judge.

This is an action to enforce an Internal Revenue Service summons. The respondent, as trustee of a family trust, argues that the request should be denied for two reasons: (1) The records were subject to a physician-patient privilege, and (2) The summons is “unreasonable” under 26 U.S.C. § 7605. The respondent is a chiropractor. He has set up a family trust and made all the records of the chiropractory practice records of the trust. The Internal Revenue Service seeks all of the records of the family trust’s financial transactions, including…