In Re the Summons Issued to Ernst & Young, LLP

TIMMONS-GOODSON, Justice.

The dispositive issue in this appeal is whether the Rules of Civil Procedure apply to summons enforcement proceedings under N.C.G.S. § 105-258(a). We hold that the Rules of Civil Procedure do not apply to such proceedings, and we therefore modify, affirm in part, and remand the decision of the Court of Appeals.

I. Background

Beginning in 1995 Ernst & Young, LLP (“Ernst & Young”), a global professional-services firm, sold to Wal-Mart Stores, Inc. (“Wal-Mart”) a number of tax shelters designed to reduce Wal-Mart’s income tax liability to various states, including North…