UNITED STATES v. ZOLIN

Nos. 85-6065, 85-6105.

809 F.2d 1411 (1987)

UNITED STATES of America, Petitioner/Appellee/Cross-Appellant, v. Frank S. ZOLIN, Respondent/Appellee, and Church of Scientology of California and Mary Sue Hubbard, Intervenors/Appellants/Cross-Appellees.

United States Court of Appeals, Ninth Circuit.

Decided February 9, 1987.


Attorney(s) appearing for the Case

Eric M. Lieberman and Edward Copeland, Michael Lee Hertzberg, New York City, and Donald C. Randolph, Los Angeles, Cal., for intervenors/appellants/cross-appellees.

Frederick Bennett, Co. Counsel, Los Angeles, Cal., for defendant/appellee.

John A. Dudeck, Jr., Tax Div., Dept. of Justice, Washington, D.C., and Charles H. Magnuson, Asst. U.S. Atty., Los Angeles, Cal., for petitioner/appellee/cross-appellant.

Before BROWNING, Chief Judge, GOODWIN and FARRIS, Circuit Judges.


FARRIS, Circuit Judge:

In July 1984, the Criminal Investigation Division of the IRS (Los Angeles District) began investigating L. Ron Hubbard's tax returns for the tax years 1979 through 1983. In October, the IRS served an administrative summons on the Clerk of the Los Angeles County Superior Court and requested that he produce certain documents relating to Hubbard's potential tax liability. (The Superior Court had obtained the documents in connection with an unrelated...

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