United States v. Schoendorf

This is an appeal from an order of the district court1 granting enforcement of two Internal Revenue Service summonses issued to respondents herein on January 12, 1970, pursuant to Title 26 U.S. C.A. § 7602, Internal Revenue Code of 1954.2

The underlying facts, as found by the trial court, disclose that Joseph F. Schoendorf, Sr., and his two sons, Joseph F. Schoendorf, Jr. and Thomas J. Schoendorf, individually and independently practiced law out of the same office in Milwaukee, Wisconsin. In the course of a Collection Division delinquency investigation, IRS Officer Mallow determined that…