United States v. Schoeberlein

THOMSEN, District Judge.

This is a proceeding brought by the United States and a Special Agent of the Internal Revenue Service (IRS) under §§ 7402(b) and 7604(a), I.R.C. 1954, 1 to compel compliance with an administrative summons issued to William E. Schoeberlein, the attorney-accountant for taxpayers, J. Stewart Brinsfield and his wife, demanding the production of certain financial records and work papers in Schoeberlein’s possession on the date of service of the summons and alleged to be necessary to a determination of the Brinsfields’ tax liabilities for the years 1965, 1966, 1967 and 1968.…