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UNITED STATES v. LASK

No. 82-1526.

703 F.2d 293 (1983)

UNITED STATES of America, and Mark W. Lawler, Special Agent of the Internal Revenue Service, Appellees, v. James E. LASK and Ruth L. Lask, Appellants.

United States Court of Appeals, Eighth Circuit.

Decided March 30, 1983.

Attorney(s) appearing for the Case

Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, Charles E. Brookhart, William P. Wang, Attys., Tax Div., Dept. of Justice, Washington, D.C., for appellees; Thomas E. Dittmeier, U.S. Atty., St. Louis, Mo., of counsel.

Lashly, Caruthers, Baer & Hamel, P.C., Michael G. Goldstein, James J. Hennelly, Alan D. Pratzel, St. Louis, Mo., for appellants.

Before LAY, Chief Judge, and McMILLIAN and JOHN R. GIBSON, Circuit Judges.

JOHN R. GIBSON, Circuit Judge.

Taxpayers James E. Lask and Ruth L. Lask appeal from the district court* order directing enforcement of Internal Revenue Service summonses issued to various third-party recordkeepers. Taxpayers contend (1) that the IRS acted in bad faith in carrying out the investigation, (2) that a portion of the time period covered by the IRS summonses is barred by the statute...

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