United States v. James B. Cardwell, United States of America v. Marvin Martin

SNEED, Circuit Judge:

Cardwell was convicted of aiding in preparation of a false corporate tax return, his codefendant Martin was convicted of willfully subscribing to a false corporate tax return, and both were convicted of conspiracy. After a bench trial, each was sentenced to twenty-five weekends in jail, 2000 hours charitable service, and five years probation. This appeal followed. We reverse the convictions on the ground that the search warrant executed by the Internal Revenue Service (IRS) during its investigation did not satisfy the particularity requirement of the Fourth Amendment, but…