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U.S. v. SCHMIDT

No. 85-2337.

816 F.2d 1477 (1987)

UNITED STATES of America and Richard Kawabata, Revenue Agent, Internal Revenue Service, Petitioners-Appellees, v. Ralph W. SCHMIDT and Reeda Schmidt, Respondents-Appellants.

United States Court of Appeals, Tenth Circuit.

April 27, 1987.

Attorney(s) appearing for the Case

Francis M. Wikstrom (W. Mark Gavre, with him on the briefs) of Parsons, Behle & Latimer, Salt Lake City, Utah, for respondents-appellants.

Robert S. Parish, Jr., Broomfield, Colo. (Roger M. Olsen, Acting Asst. Atty. Gen., Michael L. Paup, Charles E. Brookhart, Attys., Tax Div., Dept. of Justice, Washington, D.C., Brent D. Ward, U.S. Atty., Salt Lake City, Utah, with him on the brief), for petitioners-appellees.

Before BARRETT and TACHA, Circuit Judges, and BROWN, Senior District Judge.

WESLEY E. BROWN, Senior District Judge.

Appellants Ralph W. and Reeda Schmidt appeal from a District Court order enforcing summonses issued by the Internal Revenue Service. 26 U.S.C. Secs. 7402(b) and 7604(a). We affirm the enforcement order of the District Court.

The facts are not in dispute. On July 3, 1984, the IRS issued administrative summonses to appellants, pursuant to 26 U.S.C. Sec. 7602 (1982). The summonses directed appellants to appear before Revenue...

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