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UNITED STATES v. WILL

No. 80-3680.

671 F.2d 963 (1982)

UNITED STATES of America and Dennis J. Hanzel, Special Agent, Internal Revenue Service, Plaintiffs-Appellees, v. Jay T. WILL, Defendant-Appellant.

United States Court of Appeals, Sixth Circuit.

Decided February 24, 1982.

Attorney(s) appearing for the Case

Eugene Matan, Columbus, Ohio, for defendant-appellant.

Albert Ritcher, Asst. U. S. Atty., Columbus, Ohio, John F. Murray, Acting Asst. Atty. Gen., Michael L. Paup, William A. Whitledge, Philip I. Brennan, Dept. of Justice, Tax Div., Washington, D. C., for plaintiffs-appellees.

Before BROWN and JONES, Circuit Judges, and PHILLIPS, Senior Circuit Judge.

NATHANIEL R. JONES, Circuit Judge.

Appellant Jay T. Will appeals from the district court's order granting enforcement of an Internal Revenue Service (IRS) summons. Appellant contends that the summons was issued in bad faith and for purposes of harassment. He also urges that the district court erred in limiting his attempt to prove this fact. For the reasons stated below, we affirm the district court's decision.

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