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WOLF v. C.I.R.

No. 92-2488.

13 F.3d 189 (1993)

M.A. WOLF, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided December 30, 1993.

Attorney(s) appearing for the Case

H. Louis Sirkin (briefed) and Edmund McKenna (argued), Sirkin, Pinales, Mezibov & Schwartz, Cincinnati, OH, for petitioner-appellant.

Gary R. Allen, Acting Chief (briefed), Jonathan S. Cohen, and Kenneth W. Rosenberg (argued), U.S. Dept. of Justice, Appellate Section Tax Div., Washington, DC, for respondent-appellee.

Before: NORRIS and SILER, Circuit Judges; and OAKES, Senior Circuit Judge.

OAKES, Senior Circuit Judge.

The issue in this appeal is whether the exclusionary rule applies in civil tax proceedings to bar the admission of evidence seized in an allegedly illegal search conducted in furtherance of a criminal narcotics investigation. We are required by the decisions of the Supreme Court to apply the exclusionary rule in this intrasovereign context only if application would deter future violations of the Fourth Amendment. We conclude that tax deficiency...

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