Pierre v. United States

MEMORANDUM OPINION AND ORDER

WINGATE, District Judge.

This action was filed by the taxpayer, Joseph M. Pierre, M.D., [hereinafter Pierre] against the respondent, United States of America, pursuant to 26 U.S.C. § 7609(h) 1 of the Internal Revenue Code, to quash an Internal Revenue summons for certain tax documents of the taxpayer’s in the possession of A1 Roberts/Custom Accounting Systems, Inc., of Mississippi, 2 which is a “third-party recordkeeper” as defined in section 7609(a)(3) 3 of the Internal Revenue Code of 1986 (26 U.S.C.). Pursuant to Rule 12(b)(6) 4 of the Federal Rules of Civil…