Richie H. Conner v. United States

Affirmed by published opinion. Senior Judge HAMILTON wrote the opinion, in which Judge LUTTIG and Judge MICHAEL joined.

OPINION

HAMILTON, Senior Circuit Judge:

Richie H. Conner (Conner), the subject of an ongoing criminal tax investigation, appeals the district court’s order: (1) dismissing his petitions to quash certain summonses issued by the Internal Revenue Service (IRS) to two third-party record keepers; and (2) granting the government’s cross motion for enforcement of such summonses. We affirm.

I

Since the early 1970s, Conner has owned and operated Shags Lumber Company, a sole proprietorship…