DiANDRE v. U.S.

No. 90-1339.

968 F.2d 1049 (1992)

Anthony F. DiANDRE, Plaintiff, and Metro Denver Maintenance Cleaning, Inc., Plaintiff-Appellee, v. UNITED STATES of America, Defendant-Appellant.

United States Court of Appeals, Tenth Circuit.

July 7, 1992.


Attorney(s) appearing for the Case

Steven W. Parks, Atty., Tax Div., U.S. Dept. of Justice (Shirley D. Peterson, Asst. Atty. Gen., Gary R. Allen and Jonathan S. Cohen, Attys., Tax Div., U.S. Dept. of Justice, with him on the brief), Washington, D.C., for defendant-appellant.

Thomas G. Hodel of Doussard Hodel & Markman, P.C., Lakewood, Colo., for plaintiff-appellee.

Before MOORE, ANDERSON, and EBEL, Circuit Judges.


EBEL, Circuit Judge.

In this appeal, we consider whether, and to what extent, section 6103 of the Internal Revenue Code ("I.R.C.") (26 U.S.C. § 6103) limits the scope of an Internal Revenue Service ("IRS") investigation. We hold that IRS circular letters sent to the taxpayer's customers requesting information on all payments made to the taxpayer did not violate section 6103. Accordingly, we reverse the district court's judgment awarding damages to the taxpayer...

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