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SHISLER v. U.S.

No. 99-3027.

199 F.3d 848 (1999)

Douglas R. SHISLER, Mary Ann Shisler, Libera Services Company Ltd., Shisler Family Irrevocable Trust, MDS Global Company, Cypress Funds, Inc., MDS International, Petitioners-Appellants, v. UNITED STATES of America, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided and Filed: December 28, 1999.

Attorney(s) appearing for the Case

Matthew Gilmartin (argued and briefed), Rocky River, Ohio, Joe A. Izen, Jr., Izen & Associates, P.C., Bellaire, TX, for Petitioners-Appellants.

Annette G. Butler, Assistant U.S. Attorney, Cleveland, Ohio, John A. Dudeck (argued and briefed), Charles E. Brookhart (briefed), U.S. Department of Justice, Appellate Section Tax Division, Washington, D.C., Joel L. McElvain, U.S. Department of Justice, Tax Division, Appellate Section, Washington, DC, for Respondent-Appellee.

Before: KEITH, CONTIE, and NORRIS, Circuit Judges.

OPINION

CONTIE, Circuit Judge.

Petitioners-appellants, Douglas Shisler, et al., appeal the judgment of the district court, dismissing their petition to quash IRS summonses to third-party recordkeepers because the petition was untimely filed. For the following reasons, we affirm.

I. Facts

The Internal Revenue Service ("IRS"), pursuant to an income tax investigation of petitioner Shisler and several trusts of which he is the trustee ("petitioners...

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