Clay v. United States
Court of Appeals for the Sixth Circuit
1Opinion of the Court
OPINION
CONTIE, Circuit Judge.
Petitioners-appellants, Ezekiel Clay IV, et al., appeal the judgment of the district court dismissing their petition to quash IRS summonses to a third-party record-keeper because the petition was untimely filed. For the following reasons, we affirm.
I
The Internal Revenue Service (“IRS”), pursuant to an income tax investigation of petitioner Clay and several trusts of which he is the trustee (“petitioners”), issued seven summonses to a third-party record-keeper, Key Bank of Dayton, Ohio, on June 16, 1998, requesting information regarding the tax liability of Mr.…
2Cases cited13 opinions
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- United States Department of Energy v. OhioSupreme Court of the United States · 1992
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