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  5. 718 F.2d 1015 (1983)
 

MATTER OF NEWTON

Nos. 82-8586, 83-8056.

718 F.2d 1015 (1983)

In the Matter of The Tax Liability of Willis H. NEWTON, Lee M. Newton and Trio Manufacturing Company, Intervenors-Appellants, UNITED STATES of America, and Douglas P. McCallum, special agent, Internal Revenue Service, Plaintiffs-Appellees, v. George B. PENNINGTON, CPA, Defendant. UNITED STATES of America and Douglas P. McCallum, Special Agent, IRS, Plaintiffs-Appellants, v. George B. PENNINGTON, CPA, Defendant-Appellee.

United States Court of Appeals, Eleventh Circuit.

November 3, 1983.

Attorney(s) appearing for the Case

Ralph H. Greil, Atlanta, Ga., for Pennington.

Jere W. Morehead, Asst. U.S. Atty., Atlanta, Ga., Glen L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, Chief, Appellate Section, Carleton D. Powell, William A. Whitledge, Tax Div., Dept. of Justice, Washington, D.C., for U.S. and Mc Callum.

Robert H. Hishon, Atlanta, Ga., John D. Comer, Macon, Ga., for Newton, et al.

Before JOHNSON and HENDERSON, Circuit Judges, and ALLGOOD, District Judge.

JOHNSON, Circuit Judge:

These consolidated appeals present the question whether tax accrual workpapers prepared by an independent auditor of a closely held corporation may be subject to summons by the Internal Revenue Service ("IRS") without a special showing of particularized need for the material sought. We hold that tax accrual workpapers are subject to IRS summons without any special showing and, accordingly, we affirm the order enforcing the summons in this case...

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