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SCOTTY'S CONTRACTING AND STONE, INC. v. U.S.

No. 01-6587.

326 F.3d 785 (2003)

SCOTTY'S CONTRACTING AND STONE, INC., Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided and Filed April 24, 2003.

Attorney(s) appearing for the Case

Robert C. Webb (argued and briefed), Theresa A. Canaday (briefed), Frost, Brown, Todd LLC, Louisville, KY, for Plaintiff-Appellant.

Stuart D. Gibson, U.S. Dept. of Justice, Tax Div., Frank P. Cihlar (briefed), U.S. Dept. of Justice, Appellate Section Tax Division, Washington, DC, Judith A. Hagley (argued and briefed), Tax Div., Dept. of Justice, Washington, DC, for Defendant-Appellee.

Before MOORE and GIBBONS, Circuit Judges; COHN, Senior District Judge.

OPINION

GIBBONS, Circuit Judge.

The appellant, Scotty's Contracting & Stone Company (Scotty's), filed this action seeking to quash two third-party summonses issued by the Internal Revenue Service to Scotty's accountants. The district court denied Scotty's petition to quash and granted the government's motion for summary enforcement of the summonses. Scotty's appeals. For the following reasons, we affirm.

In 1998, the IRS initiated an investigation...

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