United States of America, and Lori Nicholls, Internal Revenue Agent v. C.E. Hobbs Foundation for Religious Training and Education, Inc.

FERGUSON, Circuit Judge.

The Internal Revenue Service (IRS) appeals from the district court’s denial of the IRS’ motion to enforce two summonses, one against C.E. Hobbs Foundation for Religious Training and Education, Inc. (Foundation) and the other against the Washington Trust Bank (Bank) as third party record keeper of the Foundation’s financial records. The district court refused to enforce either summons because it found that the IRS had failed to show that the requested documents were necessary to determine whether the Foundation was liable for any taxes or to determine whether the…