United States v. Spezzano

TELESCA, District Judge.

In this proceeding brought pursuant to 26 U.S.C. 7402(b) and 7604(a), the Internal Revenue Service (IRS) seeks judicial enforcement of three summonses requiring the production of certain records which are currently in the possession of the respondents. The three summonses were served upon the taxpayer, Frank Avery; the taxpayer’s accountant, Gerald Spezzano; and the taxpayer’s attorney, William Neild, Esq. All three summonses seek the production of the same documents: the accountant’s original workpapers along with the accountant’s original working drafts of several…