United States Second Circuit

Dismissal of several petitions to quash a third-party summons issued by the IRS to an investment broker as part of an investigation into potential tax liabilities arising from the sale of stock, and granting the government's counterclaim to enforce the summons, are affirmed as the purpose of the summons is legitimate under U.S. v. Powell, 379 U.S. 48 (1964) regardless of whether petitioners reside in the U.S. Virgin Islands.

Appellate Information

• Decided 03/16/2007
• Published 03/16/2007

Judges

• PER CURIAM., Before WINTER, WALKER, and STRAUB, Circuit Judges.

Court

• United States Second Circuit

Counsel

• For Appellant:
  
• Joseph M. Erwin (Steven M. Nachman, on the brief), Dallas, TX, for Petitioners-Appellants.


• For Appellees:
  
• Sarah E. Light, Assistant United States Attorney (Michael J. Garcia, United States Attorney, Southern District of New York, Sean H. Lane, Assistant United States Attorney, on the brief), New York, NY, for Respondent-Appellee.