Cohen v. United States

MEMORANDUM

DALZELL, District Judge.

Xélan, The Economic Association of Health Care Professionals, is a California-based organization that has marketed “tax reduction plans” and other services to tens of thousands of physicians under the leadership of dentist-cum-financial guru L. Donald Guess. 1 Pursuant to an investigation into the tax liability of two xélan members, Doctors David and Margaret Cohen, the Internal Revenue Service has issued summonses directing SEI Private Trust Company of Oaks, Pennsylvania, to produce documents relating to a disability trust program with more than $400 million…