United States and Special Agent Gail R. Kohorst of the Internal Revenue Service v. Darwin Construction Company, Inc. Lester J. Robinson

DONALD RUSSELL, Circuit Judge:

Darwin Construction Company and its president and sole shareholder, Lester J. Robinson, appeal from an order of the district court which imposed a $30,000 civil contempt fine against Darwin Construction Company, 1 and from the district court’s subsequent denial of its motion to set aside or reduce the fine. 2 For the reasons set forth below, we modify the district court’s assessment of the civil contempt fine, and as modified, we affirm the assessment.

I

On May 2, 1985, the Internal Revenue Service (“IRS”) served a summons on Lester J. Robinson (“Robinson”)…