United States Fifth Circuit

Under the Convention Between the Government of the United States and the Government of the French Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Tax on Income, party challenging an IRS summons must show bad faith on the part of the IRS, not the French government.

Appellate Information

• Decided 11/07/2001
• Published 11/07/2001

Judges

• WIENER, Circuit Judge:, Before GARWOOD and WIENER, Circuit Judges, and CLEMENT, District Judge.

Court

• United States Fifth Circuit

Counsel

• For Appellant:
  
• Michael A. Mayhall (argued), John Julius Steger, IV, Michael A. Mayhall, New Orleans, LA, for Plaintiff-Appellant.


• For Appellees:
  
• Robert J. Branman (argued), Frank P. Cihlar, U.S. Dept. of Justice, Tax Div., Washington, DC, for Defendant-Appellee.