Xélan, Inc. v. United States

MEMORANDUM OPINION

TITUS, District Judge.

On May 24, 2004, the Internal Revenue Service (“IRS”) issued an administrative summons directed to Johnson Lambert and Company (“Johnson Lambert”) in connection with its investigation of Petitioner, xélan, Inc (“xélan”). In response, xélan filed a Petition to Quash the IRS administrative summons, pursuant to 26 U.S.C. § 7609(b)(2). Respondent, the United States, filed a Motion for Summary Enforcement of the administrative summons. Pursuant to 26 U.S.C. § 7609(h), this Court is granted jurisdiction to resolve the dispute.

I

This case involves an IRS…