United States v. Administrative Enterprises, Incorporated, Principal Services, Incorporated, Zion Ventures, Incorporated
Court of Appeals for the Seventh Circuit
1Opinion of the Court
POSNER, Chief Judge.
In 1990 the Internal Revenue Service, pursuant to 26 U.S.C. § 7602(a) (on which see generally Reisman v. Caplin, 375 U.S. 440, 84 S.Ct. 508, 11 L.Ed.2d 459 (1964)), issued a summons to Principal Services, Inc., seeking documents relating to transactions with Burton and Naomi Kanter, whose tax liability the IRS was investigating. Principal Services did not respond, but it was not until three and a half years after the issuance of the summons that the United States got around to asking for an order enforcing it. 26 U.S.C. § 7402(b); Reisman v. Caplin, supra, 375 U.S. at…
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