Wheeler v. United States

MEMORANDUM ORDER

MCLAUGHLIN, District Judge.

This matter concerns an administrative summons served by the Internal Revenue Service (“IRS”) upon the First National Bank relative to the IRS’s investigation into the federal income tax liabilities of Petitioner E. Merwin Wheeler for the years 1999 through and including 2005. Wheeler failed to file federal income tax returns for those years and, consequently, the IRS initiated an investigation under 26 U.S.C. § 7601 to determine the amount of income received by Wheeler during that period.

Wheeler filed a petition to quash the summons, arguing that…