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UNITED STATES v. CENTENNIAL BUILDERS, INC.

No. 83-7524.

747 F.2d 678 (1984)

UNITED STATES of America, Frank A. McCammon, Special Agent, Internal Revenue Service, Plaintiffs-Appellees, v. CENTENNIAL BUILDERS, INC., Charles H. Erwin, et al., Defendants, Charles H. Erwin, Fred D. Jones, Jones-Erwin Industries, Inc., and O.H.M., Inc., Intervenors-Appellants.

United States Court of Appeals, Eleventh Circuit.

November 28, 1984.

Attorney(s) appearing for the Case

John M. Bray, David J. Curtin (argued), Washington, D.C., for Fred D. Jones.

Frederick G. Helmsing, Mobile, Ala., for Charles H. Erwin, Jones-Erwin Ind., Inc. and O.H.M., Inc.

Ginny S. Granade, Asst. U.S. Atty., Mobile, Ala., Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, Chief Appellate Section, Charles E. Brookhart, John A. Dudeck, Jr. (argued), Tax Div., Dept. of Justice, Washington, D.C., for plaintiffs-appellees.

Before TJOFLAT, HILL and JOHNSON, Circuit Judges.

JAMES C. HILL, Circuit Judge:

Appellant-Taxpayers appeal from a district court order enforcing eight Internal Revenue Service administrative summonses. We affirm the order, finding no improper purpose on the part of the IRS nor any constitutional infirmities that would prevent enforcement.

I. BACKGROUND

Special Agent Frank McCammon of the Criminal Investigation Division of the IRS was assigned to conduct a tax investigation of appellants Fred D....

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