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UNITED STATES v. COATES

Nos. 82-4013, 82-4025.

692 F.2d 629 (1982)

UNITED STATES of America and Charles W. Brown, Revenue Agent, Appellants/Cross-Appellees, v. Edwin R. COATES, as Representative of Church of Reflection, Inc., Appellee/Cross-Appellant.

United States Court of Appeals, Ninth Circuit.

Decided November 18, 1982.

Attorney(s) appearing for the Case

Dan Ross, Tax Division, Dept. of Justice, Washington, D.C., for U.S.A.

John M. Youngquist, San Francisco, Cal., for Coates.

Before BROWNING, PREGERSON and POOLE, Circuit Judges.

PREGERSON, Circuit Judge:

The Internal Revenue Service (IRS) brought an action in the district court, 526 F.Supp. 248, to enforce an IRS summons for production of financial, corporate, and religious records of the Church of Reflection, Inc. (Church). The summons1 was directed to Edwin Coates, as representative of the Church, for the purpose of investigating the Church's qualification for tax exempt...

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