United States v. Kemper Money Market Fund, Inc.

BAUER, Circuit Judge.

This is an appeal from the district court’s denial of taxpayers’ motions to intervene in civil summons enforcement proceedings brought by the Internal Revenue Service (IRS) against certain financial institutions that maintained records of these taxpayers’ accounts. The district court denied taxpayers’ motions on the ground that these taxpayers had not made a sufficient showing that the IRS lacked the requisite civil purpose for its investigation of their financial records, and, in turn, their tax liabilities. Because the district court failed to consider the taxpayers’…