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U.S. v. NORWEST CORP.

Nos. 96-2792, 96-2793.

116 F.3d 1227 (1997)

UNITED STATES of America, Appellee, v. NORWEST CORPORATION, Appellant; Arthur Andersen & Co., Intervenor-Appellant.

United States Court of Appeals, Eighth Circuit.

Decided June 26, 1997.

Attorney(s) appearing for the Case

James A. Bruton, III, Washington, DC, argued (James P. Holden, Susan H. Serling and J. William Koegel, Jr., on the brief), for Arthur Andersen & Co.

Walter A. Pickhardt, Minneapolis, MN, argued (Nathan P. Zietlow and Mark Alan Hagar, on the brief), for Norwest Corp.

John A. Dudeck, Jr., Dept. of Justice, Washington, DC, argued (Loretta C. Argrett and Charles E. Brookhart, on the brief), for U.S.

Before WOLLMAN and BEAM, Circuit Judges, and LAUGHREY, District Judge.

BEAM, Circuit Judge.

In the course of an audit of Norwest Corporation, the Internal Revenue Service sought to enforce a designated summons directing Norwest to produce tax preparation software licensed to it by Arthur Andersen & Co., as well as related documents and data. Norwest and Andersen objected to the summons, claiming that the material was not within the scope of the IRS's authority, and that in any event it...

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