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U.S. v. ADMINISTRATIVE ENTERPRISES, INC.

No. 94-2548.

46 F.3d 670 (1995)

UNITED STATES of America, Petitioner-Appellee, v. ADMINISTRATIVE ENTERPRISES, INCORPORATED, Principal Services, Incorporated, Zion Ventures, Incorporated, et al., Respondents-Appellants.

United States Court of Appeals, Seventh Circuit.

Decided February 2, 1995.

Attorney(s) appearing for the Case

Gary R. Allen, William Patton (argued), Dept. of Justice, Tax Div., Appellate Section, Douglas W. Snoeyenbos, Dept. of Justice, Tax Div., Appellate Section, Washington, DC, for petitioner-appellee.

Ramune R. Kelecius, Office of U.S. Atty., Civ. Div., Harvey M. Silets (argued), Karyn G. Gershon, Nicole N. Auerbach, Katten, Muchin & Zavis, Chicago, IL, for respondents-appellants.

Before POSNER, Chief Judge, and REAVLEY and COFFEY, Circuit Judges.

POSNER, Chief Judge.

In 1990 the Internal Revenue Service, pursuant to 26 U.S.C. § 7602(a) (on which see generally Reisman v. Caplin, 375 U.S. 440, 84 S.Ct. 508, 11 L.Ed.2d 459 (1964)), issued a summons to Principal Services, Inc., seeking documents relating to transactions with Burton and Naomi Kanter, whose tax liability the IRS was investigating. Principal Services did not respond, but it was not until three and a half...

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