United States First Circuit

Fed. R. Civ. P. 6(e), allowing three additional days to the proscribed period of acting when notice is mailed, does not apply to 26 USC 7609, requiring the IRS to give notice to the taxpayer when issuing a third-party record keeper summons.

Appellate Information

• Decided 09/05/2001
• Published 09/05/2001

Judges

• BOUDIN, Chief Judge., Before BOUDIN, Chief Judge, SELYA and LIPEZ, Circuit Judges.

Court

• United States First Circuit

Counsel

• For Appellant:
  
• Bruce A. Singal with whom Donoghue, Barrett & Singal, P.C. was on brief for appellant., Kenneth W. Rosenberg, Tax Division, Department of Justice, with whom Claire Fallon, Acting Assistant Attorney General, Donald K. Stern, United States Attorney, and David English Carmack, Tax Division, Department of Justice, were on brief for the United States.