David S. Spell v. United States of America, J. Darlene Dupree, (Two Cases)

WILKINSON, Circuit Judge:

Taxpayer David S. Spell appeals the judgment of the district court granting summary enforcement of Internal Revenue Service summonses against his accountant and First Federal of Charleston. The summonses were issued during an investigation of possible income tax fraud. Spell claims, inter alia, that the summonses by the Criminal Investigation Division constitute an “unnecessary examination” prohibited by 26 U.S.C. § 7605(b) because a revenue agent previously examined some of the same documents now sought. We hold that the reexamination of a taxpayer’s records in the…