Kroll v. United States

MEMORANDUM AND ORDER

SHARP, Chief Judge.

This cause is presently before the court on the Motion to Dismiss Petition to Quash Internal Revenue Summons and For an Award of Attorney’s Fees and Costs of Respondents, United States of America and the Internal Revenue Service (IRS).

The facts underlying this cause of action are as follows. The IRS summonses involved were issued during an investigation of the federal tax liabilities of Louis E. Kroll and Helen M. Kroll (taxpayers). On April 16, 1982, the IRS, through its agent Donald Kempf, issued two IRS summonses to Carol Bradshaw, Audit Secretary,…