U.S. v. DYNAVAC, INC.

Nos. 91-56376, 91-56539.

6 F.3d 1407 (1993)

UNITED STATES of America; Ronald Sheresh, Revenue Agent, Internal Revenue Service, Plaintiffs/Petitioners/Appellees, v. DYNAVAC, INC.; Donald J. Helmer; and Morgan T. Wright, Defendants/Respondents/Appellants. UNITED STATES of America; Ronald Sheresh, Revenue Agent, Internal Revenue Service, Plaintiffs/Petitioners/Appellees, v. Curtis J. CORN, Defendant/Respondent/Appellant.

United States Court of Appeals, Ninth Circuit.

Decided October 8, 1993.


Attorney(s) appearing for the Case

James A. Bruton, Acting Asst. Atty. Gen.; Gary R. Allen, Charles E. Brookhart, Joel A. Rabinovitz, Attys., Tax Div., Dept. of Justice, Washington, DC, for plaintiffs/petitioners/appellees U.S. of America and Ronald Sheresh.

Donald Helmer, Morgan T. Wright, Dynavac, Inc., in pro per.

Robert K. Smith, La Jolla, CA, for defendant/respondent/appellant Curtis J. Corn.

Before: KOZINSKI, SUHRHEINRICH and T.G. NELSON, Circuit Judges.


SUHRHEINRICH, Circuit Judge:

In this consolidated appeal, Dynavac, Inc., Donald J. Helmer, and Morgan T. Wright (91-56376) and Curtis J. Corn (91-56539) (collectively "respondents") appeal the district court's orders enforcing summonses of the Internal Revenue Service ("IRS" or "government"), pursuant to 26 U.S.C. §§ 7601 and 7602, to examine their business records which are being held by the United States Attorney. The principal issue we consider is whether...

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