HINTZE v. I.R.S.

Nos. 88-1320, 88-1347.

879 F.2d 121 (1989)

Fritz W. HINTZE; Ledagole R. Hintze, Plaintiffs-Appellants, v. INTERNAL REVENUE SERVICE; Jeffrey Breault, Special Agent; United States of America, Defendants-Appellees (Two Cases).

United States Court of Appeals, Fourth Circuit.

Decided July 13, 1989.

Rehearing and Rehearing Denied August 18, 1989.


Attorney(s) appearing for the Case

William Allen Cohan (Cohan & Greene, on brief), for plaintiffs-appellants.

William Anthony Whitledge (Gary R. Allen, Charles E. Brookhart, Tax Div., Dept. of Justice, Washington, D.C., William S. Rose, Jr., Asst. Atty. Gen., Henry E. Hudson, Alexandria, Va., Breckinridge L. Willcox, U.S. Attys., Washington, D.C., on brief) for defendants-appellees.

Before PHILLIPS and WILKINSON, Circuit Judges, and BUTZNER, Senior Circuit Judge.


Rehearing and Rehearing In Banc Denied August 18, 1989.

PHILLIPS, Circuit Judge:

In this consolidated appeal, Frederick W. and Ledagole R. Hintze challenge two district court orders summarily enforcing a number of Internal Revenue Service summonses issued to obtain certain records held by third parties and allegedly sought for the purpose of determining the appellants' tax liability for calendar years 1984 through 1986.

In No. 88-1320, we find that...

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