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UNITED STATES v. WALL CORPORATION

No. 72-1767.

475 F.2d 893 (1972)

UNITED STATES of America and Thornton J. Camfield, Special Agent, Internal Revenue Service v. WALL CORPORATION et al., Appellants.

United States Court of Appeals, District of Columbia Circuit.

December 13, 1972.

Attorney(s) appearing for the Case

Mr. Raymond G. Larroca, Washington, D. C., with whom Messrs. Herbert J. Miller, Jr., and William H. Jeffress, Jr., Washington, D. C., were on the brief, for appellants.

Mr. John Mullenholz, Arlington, Va., of the bar of the Court of Appeals of Maryland, pro hac vice, by special leave of court, with whom Messrs. Scott P. Crampton, Asst. Atty. Gen., Crombie J. D. Garrett and Robert E. Lindsay, Attys., Department of Justice, were on the brief, for appellees.

Before McGOWAN, ROBINSON and MacKINNON, Circuit Judges.

PER CURIAM:

The questions presented by this appeal are whether an Internal Revenue Service summons, issued pursuant to 26 U.S.C. § 7602, requiring Wall Corporation to produce books, records, expense vouchers and other data relevant to the tax liability of Daniel C. and Roslyn Wall was issued for a proper purpose, and whether the District Court erred in refusing to permit Wall Corporation discovery designed to adduce the purpose of

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