Boyd v. United States

OPINION

MOORE, Circuit Judge.

James Clay Boyd and Debra E. Boyd (“the Boyds”) appeal from the denial of their petition to quash Internal Revenue Service (“IRS”) summonses issued for records in the possession of them accountant, R. Douglas Anderson (“CPA Anderson”). *483They argue that certain technical deficiencies in process render the summonses unenforceable. For the reasons that follow, we AFFIRM the judgment of the district court.

IRS Special Agent J. Trent Tyson (“Agent Tyson”) was conducting a criminal investigation concerning the federal income tax liability of James Clay Boyd (“Boyd”),…