United States v. Allen F. Campbell and A.F. Campbell & Co., Inc.

POLITZ, Circuit Judge:

Allen F. Campbell and A.F. Campbell & Co., Inc. (hereinafter sometimes “Campbell”) appeal a permanent injunction entered pursuant to section 7408 of the Internal Revenue Code, 1 contending that the conduct complained of did not fall within the reach of section 6700 of the Code and, further, that the injunction is overly broad. Subject to the construction given and modification made, we affirm.

Background

Allen F. Campbell is an attorney with a master’s degree in business administration. He is the sole shareholder in both A.F. Campbell & Co., Inc., a Texas corporation, and…