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U.S. v. MICHAUD

Nos. 89-1684, 89-1986.

907 F.2d 750 (1990)

UNITED STATES of America and James A. Hill, Special Agent, Internal Revenue Service, Petitioners-Appellants, v. James E. MICHAUD and Mary L. Michaud, Respondents-Appellees.

United States Court of Appeals, Seventh Circuit.

Reargued May 30, 1990.

Decided July 24, 1990.

Attorney(s) appearing for the Case

Gary R. Allen, Charles E. Brookhart, Michael Roach, William A. Whitledge, James A. Bruton, Shirley D. Peterson, Mary E. Bielefeld, U.S. Department of Justice, Tax Div., Appellate Section, Washington, D.C., for petitioners-appellants.

F. Patrick Matthews, Weiss, Berzowski, Brady & Donahue, Milwaukee, Wis., for respondents-appellees.

Before BAUER, Chief Judge, CUMMINGS, WOOD, Jr., CUDAHY, POSNER, COFFEY, FLAUM, EASTERBROOK, RIPPLE, MANION and KANNE, Circuit Judges.

Reargued En Banc May 30, 1990.

BAUER, Chief Judge, joined by CUMMINGS, HARLINGTON WOOD, Jr., CUDAHY, COFFEY, FLAUM and KANNE, Circuit Judges.

In this case we reconsider United States v. Michaud, Nos. 89-1684 & 89-1986, 1990 WL 25073 (7th Cir. March 8, 1990) (attached as an appendix to the dissent hereto) ("Michaud I"), in which a panel of this court reversed an order by District Judge Terence T. Evans. Judge Evans quashed several summonses...

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