Hanna v. United States

RULING ON DEFENDANT’S MOTION TO DISMISS

SAM, District Judge.

This is an action commenced by taxpayer Rusty J. Hanna to quash Internal Revenue Service summonses served on himself and Mini Spas, Inc., and on certain other business entities.

I

Special Agent Brent D. Conlin (Agent Conlin), of the Criminal Investigation Division of the Internal Revenue Service under the District Director of the Salt Lake City District, is investigating the tax liabilities of petitioner, Rusty J. Hanna (Hanna), for the taxable periods 1981, 1982, and 1983. As part of this investigation, Agent Conlin issued six Internal…