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COPP v. U.S.

No. 92-1012.

968 F.2d 1435 (1992)

Raymond H. COPP, Jr., Petitioner, Appellant, v. UNITED STATES of America, Respondent, Appellee.

United States Court of Appeals, First Circuit.

Decided July 14, 1992.

Attorney(s) appearing for the Case

Alfred D. Ellis with whom Loren Rosenzweig and Cherwin & Glickman were on brief, for petitioner, appellant.

Sally J. Schornstheimer, Atty., Tax Div., Dept. of Justice, with whom James A. Bruton, Acting Asst. Atty. Gen., Gary R. Allen, Charles E. Brookhart, Attys., Tax Div., Dept. of Justice, and Wayne A. Budd, U.S. Atty., were on brief for respondent, appellee.

Before CYR, Circuit Judge, RONEY, Senior Circuit Judge, and PIERAS, District Judge.

PIERAS, District Judge.

This appeal stems from the issuance of an administrative summons by the Internal Revenue Service in the course of investigation into the income tax liability of appellant Raymond H. Copp for the years 1985 through 1989. The district court granted an IRS motion for summary enforcement of the summons. We affirm.

The summons, which the IRS issued pursuant to 26 U.S.C. § 7602, directed Goldman Sachs & Co., a third-party recordholder...

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