United States Fourth Circuit

Order dismissing defendant's petitions to quash certain summonses issued by the IRS to third-party record keepers and granting the government's cross motion for enforcement of such summonses is affirmed in an ongoing criminal tax investigation.

Appellate Information

• Argued 12/01/2005
• Decided 01/11/2006
• Published 01/11/2006

Judges

• Before LUTTIG and MICHAEL, Circuit Judges, and HAMILTON, Senior Circuit Judge.

Court

• United States Fourth Circuit

Counsel

• For Appellees:
  
• ARGUED:  G. Nelson Mackey, Jr., Brumberg, Mackey & Wall, P.L.C., Roanoke, Virginia, for Appellant.  Anthony Thomas Sheehan, United States Department of Justice, Tax Division, Washington, DC, for Appellee.  Paul Anthony Dull, Mark A. Black, Brumberg, Mackey & Wall, P.L.C., Roanoke, Virginia, for Appellant.   ON BRIEF:  Eileen J. O'Connor, Assistant Attorney General, Frank P. Cihlar, Tax Division, United States Department of Justice, Washington, DC;  John L. Brownlee, United States Attorney, Office of the United States Attorney, Roanoke, Virginia, for Appellee.