United States v. Barrett
Court of Appeals for the Fifth Circuit
1Per curiam
The question presented in this appeal is whether a district court can conditionally enforce an Internal Revenue Service (IRS) summons to ensure that the IRS will not violate the nondisclosure of return information provisions contained in 26 U.S.C. § 6103 while it conducts a tax investigation. We answer this question in the negative.
*1343I.
The facts giving rise to the present controversy, as set forth in the panel opinion on rehearing in United States v. Barrett, 804 F.2d 1376 (5th Cir.1986) {Barrett II), are as follows:
[Dr. Bernard M. Barrett, Jr.] is the president of an incorporated medical…
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