United States First Circuit

In a case in which the IRS is investigating civilly the failure to pay taxes and the matter has not been referred for criminal prosecution, the district court's enforcement of a summons as to foreign bank account information and documents required to be kept under the Bank Secrecy Act (BSA), 31 U.S.C. section 5311 et seq., is affirmed where the taxpayer must comply with an IRS summons for documents he or she is required to keep under the BSA. As to enforcement of the summons for documents not subject to the BSA, the judgment is reversed and remanded for further explanation.

Appellate Information

• Published 2016/03/03

Judges

• LYNCH

Court

• United States First Circuit

Counsel