UNITED STATES of America and John G. Shea, Special Agent, Internal Revenue Service, Petitioners-Appellants,
v.
COOPERS & LYBRAND et al., Respondents-Appellees, and
Johns-Manville Corporation, Respondent in Intervention-Appellee.
United States Court of Appeals, Tenth Circuit.https://leagle.com/images/logo.png
Submitted November 15, 1976.
Decided February 15, 1977.
Attorney(s) appearing for the Case
Carleton D. Powell, Atty., Tax Div., Dept. of Justice, Washington, D.C. (Scott P. Crampton, Asst. Atty. Gen., Gilbert E. Andrews, and Crombie J. D. Garrett, Attys., Tax Div., Dept. of Justice, Washington, D.C., on the brief, James L. Treece, U.S. Atty., Denver, Colo., of counsel), for petitioners-appellants.
William E. Murane, Denver, Colo. (Ben E. Chidlaw and Paul T. Ruttam, Denver, Colo., on the brief), of Holland and Hart, for respondents-appellees.
James E. Bye, Denver, Colo. (Peter H. Holme, Jr., Charles J. Kall and C. Garold Sims, Denver, Colo., on the brief), of Holme, Roberts & Owen, Denver, Colo., for respondent in intervention-appellee.
Before BARRETT and DOYLE, Circuit Judges, and CHILSON, District Judge.
United States Court of Appeals, Tenth Circuit.
BARRETT, Circuit Judge.
Petitioners-appellants,1 United States of America and John G. Shea (Shea), Special Agent, Internal Revenue Service (IRS), appeal the denial of enforcement of an IRS summons issued pursuant to 26 U.S.C.A. § 7602,2 in relation to IRS examination and audit of Johns-Manville, Inc. (J-M) corporate federal income tax returns for the years 1971...
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