United States v. Monumental Life Insurance Company

OPINION

RONALD LEE GILMAN, Circuit Judge.

Monumental Life Insurance Company appeals from the district court’s order enforcing an administrative summons issued by the Internal Revenue Service (IRS). The summons requested voluminous documents from Monumental, a third party in the IRS’s investigation of Johnson Systems, Inc. On appeal, Monumental argues that the district court erred in rejecting the magistrate judge’s findings that (1) the IRS already had in its possession many of the documents requested, and (2) the IRS’s summons was overbroad in that it sought documents not relevant to the…