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KONDIK v. U.S.

No. 95-3712.

81 F.3d 655 (1996)

James C. KONDIK and Diane S. Kondik, Petitioners-Appellants, v. UNITED STATES of America, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided April 19, 1996.

Attorney(s) appearing for the Case

James C. Kondik (Briefed), Creston, OH, for James C. Kondik.

Diane S. Kondik (Briefed), Creston, OH, for Diane S. Kondik.

Annette G. Butler, Asst. U.S. Atty., Office of the U.S. Atty., Cleveland, OH, Gary R. Allen, Acting Chief (Briefed), Charles E. Brookhart, U.S. Dept. of Justice, Appellate Section, Tax Div., Washington, DC, Thomas V. Linguanti, Tax Div., Dept. of Justice, Washington, DC, for U.S.

Before: KENNEDY, WELLFORD, and MOORE, Circuit Judges.

WELLFORD, Circuit Judge.

Taxpayers James and Diane Kondik appeal pro se the district court's denial of their petition to quash several Internal Revenue Service ("IRS") summonses issued under 26 U.S.C. § 7602 to third-party record-keepers in connection with an examination of the Kondiks' federal tax liabilities for 1991 and 1992. For the reasons stated below, we affirm the district court's ruling.

The decision to grant a petition to quash is guided...

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