United States v. Silvestain

McKAY, Circuit Judge.

The Internal Revenue Service (IRS) seeks enforcement of a summons issued to Bennie Silvestain, C.P.A., and Wenner, Silvestain and Company, C.P.A.’s ordering Mr. Silvestain to appear before Revenue Agent Shea and to produce information and documents relevant to the tax liabilities of Mr. and Mrs. Alvin Woodley.1 The requested documents were located in Mr. Silvestain’s office at the time the summons was issued.2 Taxpayer exercised his rights pursuant to section 7609(b)(2) (Supp.1981) of the Internal Revenue Code and stayed compliance with the summons. Shortly thereafter,…