Timothy Elmes v. United States

At issue in this appeal is whether the United States District Court for the Southern District of Florida properly enforced two summonses served on American Express and Northern Trust Bank, respectively, by the Internal Revenue Service (“IRS”). After thorough review, we affirm.

I

In 2002, Timothy J. Elmes claimed to be a resident of the Virgin Islands and ceased filing his U.S. tax returns. On March 22, 2006, IRS Agent Jim Keelan issued summonses to the South Florida custodians of American Express and Northern Trust Bank requesting bank account and credit card statements, correspondence, and…