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RAPP v. C.I.R.

No. 84-7490.

774 F.2d 932 (1985)

Gerald J. RAPP and Mary H. Rapp, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondents-Appellees.

United States Court of Appeals, Ninth Circuit.

Decided October 18, 1985.

Attorney(s) appearing for the Case

Gerald J. Rapp, Mary H. Rapp, Anchorage, Ark., for petitioners-appellants.

Steven Parks, Washington, D.C., for respondents-appellees.

Before BARNES, FARRIS and CANBY, Circuit Judges.

CANBY, Circuit Judge:

Gerald and Mary Rapp appeal a decision of the Tax Court granting the Commissioner's motion for summary judgment on the Rapps' petition for redetermination of tax deficiencies and additions to tax, and denying their motion to suppress notices of deficiency and certificates of assessment. We affirm.

A. Motion to Suppress

The IRS, pursuant to 26 U.S.C. § 7602, is authorized to examine records and issue summonses for...

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