United States v. Ernst & Whinney

MEMORANDUM OPINION AND ORDER

LAMBROS, District Judge.

This is an action to enforce an Internal Revenue Service (IRS) John Doe summons issued to and served upon the accounting firm of Ernst & Whinney (E&W) and its chief executive officer Ray Groves.

E&W markets nationwide an investment tax credit study (ITC study), the purpose of which is to advise its clients on methods of obtaining the maximum benefit of the investment tax credit available under 26 U.S.C. §§ 38, 46-48. After examining numerous tax returns in the Southeast United States, it was discovered that many E&W clients who had utilized…