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UNITED STATES v. OMOHUNDRO

Nos. 79-1545 to 79-1547.

619 F.2d 51 (1980)

UNITED STATES of America and Larry D. Thompson, Special Agent, Internal Revenue Service, Petitioners-Appellees, v. William D. OMOHUNDRO, Attorney at Law, Attorney for Jim's Water Service, Inc., Respondent, Jimmie D. and Cheryl Rodgers and Jim's Water Service, Inc., Intervenors-Appellants. UNITED STATES of America and Larry D. Thompson, Special Agent, Internal Revenue Service, Petitioners-Appellees, v. Larry D. HOLST, C.P.A., Respondent, Jimmie D. and Cheryl Rodgers and Jim's Water Service, Inc., Intervenors-Appellants. UNITED STATES of America and Larry D. Thompson, Special Agent, Internal Revenue Service, Petitioners-Appellees, v. Jimmie D. RODGERS, Respondent, Jimmie D. and Cheryl Rodgers and Jim's Water Service, Inc., Intervenors-Appellants.

United States Court of Appeals, Tenth Circuit.

Decided March 21, 1980.

Attorney(s) appearing for the Case

Aaron Philip Rosenfeld, Atty., Tax Div., Dept. of Justice, Washington, D. C. (M. Carr Ferguson, Asst. Atty. Gen., Gilbert E. Andrews and Charles E. Brookhart, Attys., Tax Div., Dept. of Justice, Washington, D. C.; Charles E. Graves, U. S. Atty., Cheyenne, Wyo., of counsel), for petitioners-appellees.

Joseph H. Thibodeau, Denver, Colo., for intervenors-appellants.

Before McWILLIAMS, DOYLE and McKAY, Circuit Judges.

PER CURIAM.

These consolidated appeals challenge the district court's enforcement of three administrative summonses issued by the Internal Revenue Service (IRS) during the course of an investigation of the tax liability of Jim's Water Service, Inc. Two summonses were issued respectively to the corporate taxpayer's attorney and accountant, as third-party recordkeepers and the third summons was issued to Jimmie D. Rodgers as the president of the taxpayer. The summonses...

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