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DOWD v. I.R.S.

No. 186, Docket 85-6156.

776 F.2d 1083 (1985)

John T. DOWD, Helen Dowd, and Intergold Corporation, Plaintiffs-Appellants, v. INTERNAL REVENUE SERVICE, Defendant-Appellee.

United States Court of Appeals, Second Circuit.

Decided November 13, 1985.

Attorney(s) appearing for the Case

Richard V. D'Allesandro (Richard V. D'Allesandro, P.C., Albany, N.Y., of counsel), for plaintiffs-appellants.

Glenn L. Archer, Jr. (Michael L. Paup, Richard W. Perkins, Patricia M. Bowman, Tax Div., U.S. Dept. of Justice, Washington, D.C., on brief; Frederick J. Scullin, Jr., U.S. Atty., Syracuse, N.Y., of counsel), for defendant-appellee.

Before FRIENDLY, KAUFMAN and PRATT, Circuit Judges.

PER CURIAM:

Appellants John and Helen Dowd and their wholly owned company, the Intergold Corporation, were the subjects of both criminal and civil investigations by the Internal Revenue Service. The criminal investigation ended without action being taken. The civil inquiry, however, resulted in the assessment of deficiencies, which the Dowds are now contesting in a separate action.

Pursuant to the Freedom of Information Act ("FOIA"), 5 U.S.C. § 552, the...

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