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CODNER v. U.S.

No. 93-4125.

17 F.3d 1331 (1994)

John E. CODNER, Petitioner-Appellant, v. UNITED STATES of America, Respondent-Appellee.

United States Court of Appeals, Tenth Circuit.

February 28, 1994.

Attorney(s) appearing for the Case

John E. Codner, pro se.

Michael L. Paup, Acting Assistant Attorney General, Charles E. Brookhart and Robert L. Baker, Attorneys, Tax Division, Department of Justice (Scott M. Matheson, Jr., United States Attorney, of Counsel), Washington, D.C., for respondent-appellee.

Before BALDOCK, BARRETT, and McKAY, Circuit Judges.

BALDOCK, Circuit Judge.

To determine whether petitioner-appellant John E. Codner had violated any Internal Revenue laws, the Internal Revenue Service issued twelve administrative summonses to various third parties requesting financial information regarding Codner. Codner timely filed a petition to quash the summonses on various grounds. IRS answered and filed a petition to enforce six of the summonses issued to parties residing within the District of Utah.

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