United States of America Donna Carroll, Revenue Officer of the Internal Revenue Service v. Tracy L. Brown

Appellant challenges a district court order citing him for contempt for failure to comply with its earlier order enforcing a summons requiring him to produce records to the Internal Revenue Service to determine his tax liabilities. We affirm the contempt order.

I

IRS records indicate that appellant has not filed federal income tax returns for the years 1978 through 1985. Appellee Carroll of the IRS initiated an investigation of appellant to determine his tax liabilities for those years.

On July 22, 1986, Carroll issued an internal revenue summons on appellant. The summons required that appellant…