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U.S. v. FREDERICK

Nos. 98-2644, 98-2700.

182 F.3d 496 (1999)

UNITED STATES of America, Plaintiff-Appellee, v. Richard A. FREDERICK, Defendant-Appellant, and Randolph W. Lenz, Karin Lenz, and KCS Industries, Inc., Intervening Defendants-Appellants.

United States Court of Appeals, Seventh Circuit.

Decided April 15, 1999.

Amended May 18, 1999.

Rehearing and Suggestion for Rehearing Denied July 26, 1999.

Attorney(s) appearing for the Case

Annette M. Wietecha (argued), Rachel I. Wollitzer, Dept. of Justice, Tax Div., App. Section, Washington, D.C. for Plaintiff-Appellee in No. 98-2644.

Andrew J. Levander, Swidler, Berlin, Shereff & Friedman, New York, NY, for Defendant in No. 98-2644.

Thomas L. Shriner, Jr., Foley & Lardner, Milwaukee, WI, Keith D. Krakaur (argued), Skadden, Arps, Slate, Meagher & Flom, New York, NY, for Intervenors-Appellants in No. 98-2644.

Rachel I. Wollitzer (argued), Dept. of Justice, Tax Div., Washington, DC, for Plaintiff-Appellee in No. 97-2700.

Andrew J. Levander, Swidler, Berlin, Shereff & Friedman, New York, NY, for Defendant-Appellant in No. 98-2700.

Thomas L. Shriner, Jr., Foley & Lardner, Milwaukee, WI, Kieth D. Krakaur (argued), Skadden, Arps, Slate, Meagher & Flom, New York, NY, for Intervenors in No. 98-2700.

BEFORE: POSNER, Chief Judge, and KANNE and DIANE P. WOOD, Circuit Judges.

Rehearing and Suggestion for Rehearing En Banc Denied July, 26, 1999.

POSNER, Chief Judge.

These appeals challenge an order enforcing summonses that the Internal Revenue Service issued to Richard Frederick. Frederick is both a lawyer and an accountant, and he both provides legal representation to, and prepares the tax returns of, Randolph and Karin Lenz and their company, KCS Industries, Inc. The IRS is investigating the Lenzes and their company, and the summonses...

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