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ROBERT v. U.S.

No. 03-1603.

364 F.3d 988 (2004)

Mary A. ROBERT, Plaintiff — Appellant, Siegel-Robert, Intervenor, v. UNITED STATES of America, Defendant — Appellee.

United States Court of Appeals, Eighth Circuit.

Filed: April 29, 2004.

Attorney(s) appearing for the Case

James F. Bennett, argued, St. Louis, MO (Kathleen R. Sherby and Anthony S. Gasaway, on the brief), for appellant.

Bridget M. Rowan, argued, U.S. Dept. of Justice, Tax Div., Washington, DC (Frank P. Cihlar, U.S. Dept. of Justice, Tax Div., on the brief), for appellee.

Before MELLOY, McMILLIAN, and BOWMAN, Circuit Judges.

MELLOY, Circuit Judge.

Mary A. Robert appeals the district court's1 adverse grant of summary judgment in her action to quash four separate third-party IRS summonses. We agree with Ms. Robert that the summonses issued as a result of improper ex parte communications between the IRS Appeals Office and Examination Division. See Internal Revenue Service Restructuring and Reform Act (Restructuring Act) of 1998, Pub.L. No. 105-206, 112...

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