CRYSTAL v. U.S.

No. 97-56204.

172 F.3d 1141 (1999)

John CRYSTAL; Victoria Crystal; John Crystal Pools, Inc., Petitioners-Appellants, v. UNITED STATES of America, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided April 16, 1999.


Attorney(s) appearing for the Case

Gary S. Lincenberg (argued) and Thomas R. Freeman, Bird, Marella, Boxer, Wolpert & Matz, Los Angeles, California, for the petitioners-appellants.

Charles E. Brookhart and Marion E.M. Erickson (argued), United States Department of Justice, Tax Division, Washington, D.C., for the respondent-appellee.

Before: PREGERSON and RYMER, Circuit Judges, and BURRELL, District Judge.


Opinion by Judge RYMER; Concurrence by Judge PREGERSON.

RYMER, Circuit Judge:

John Crystal, Victoria Crystal, and Crystal Pools, Inc. appeal summary judgment in favor of the government denying their petition to quash and ordering enforcement of third party summonses issued by the Criminal Investigations Division ("CID") of the Los Angeles District of the Internal Revenue Service. The Crystals initiated contact for a voluntary disclosure with the Southern California...

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