Mazurek v. United States

WIENER, Circuit Judge:

Plaintiff-Appellant Zbigniew Emilian Mazurek challenges the district court’s denial of his motion to quash the summons of the U.S. Internal Revenue Service (the “IRS”), issued in response to a request by the French Tax Authority (the “FTA”), for Mazurek’s financial records. We conclude that, because the IRS acted in good faith and met its burden under United, States v. Powell, 1 it is entitled to enforcement of its summons. We therefore affirm the ruling of the district court.

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FACTS AND PROCEEDINGS

Mazurek is the subject of an investigation by the FTA concerning his civil…