Godwin v. United States

OPINION

LATCHUM, Chief Judge.

This matter is before the Court upon the petition 1 of Harold F. Godwin (“taxpayer”), filed pursuant to 26 U.S.C. § 7609(b), to quash ten Internal Revenue Service (“IRS”) summonses 2 and the cross motion of the United States (“respondent”), filed under 26 U.S.C. § 7609(h), for summary denial of petitioner’s motion to quash three of the summonses and for summary enforcement of the seven other summonses. 3

I. Background Facts

Between January 13, 1983 and February 1, 1983, Ronald J. Poplos, a special agent with the IRS, Criminal Investigation Division, issued ten…