United States v. Omohundro

These consolidated appeals challenge the district court’s enforcement of three administrative summonses issued by the Internal Revenue Service (IRS) during the course of an investigation of the tax liability of Jim’s Water Service, Inc. Two summonses were issued respectively to the corporate taxpayer’s attorney and accountant, as third-party recordkeepers and the third summons was issued to Jimmie D. Rodgers as the president of the taxpayer. The summonses were virtually identical in scope and sought production of specific financial, accounting and other corporate records of the taxpayer.

When…