United States v. Gilbert C. Swanson Foundation, Inc.

HEANEY, Circuit Judge.

The Gilbert C. Swanson Foundation (the Foundation) appeals from an order of the district court requiring compliance with a summons issued by the Internal Revenue Service as part of an investigation into the tax liabilities of the Foundation. For reversal, the Foundation argues that the summons' was rendered invalid when an IRS agent added the name of a corporate officer to the summons after the summons had been approved by the agent’s supervisor; according to the Foundation, this departure from the procedure set forth in an IRS delegation order bars enforcement of the…