Sugarloaf Funding, LLC v. U.S. Department of the Treasury

HOWARD, Circuit Judge.

This case is one of more than a dozen in federal courts across the country related to an Internal Revenue Service (“IRS”) investigation into possible improper tax shelters. 1 As in the other cases, the targets of the investigation petitioned the district court to quash administrative summonses issued by the IRS. Approving a magistrate judge’s report and recommendation, the district court denied the motions to quash and ordered the summonses enforced. The petitioners timely appealed. Consistent with every other court to address this issue, we affirm the district court. 2

I.…