CONNER v. U.S.

No. 05-1051.

434 F.3d 676 (2006)

Richie H. CONNER, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Fourth Circuit.

Decided January 11, 2006.


Attorney(s) appearing for the Case

ARGUED: G. Nelson Mackey, Jr., Brumberg, Mackey & Wall, P.L.C., Roanoke, Virginia, for Appellant. Anthony Thomas Sheehan, United States Department of Justice, Tax Division, Washington, D.C., for Appellee. Paul Anthony Dull, Mark A. Black, Brumberg, Mackey & Wall, P.L.C., Roanoke, Virginia, for Appellant. ON BRIEF: Eileen J. O'Connor, Assistant Attorney General, Frank P. Cihlar, Tax Division, United States Department of Justice, Washington, DC; John L. Brownlee, United States Attorney, Office of the United States Attorney, Roanoke, Virginia, for Appellee.

Before LUTTIG and MICHAEL, Circuit Judges, and HAMILTON, Senior Circuit Judge.


Affirmed by published opinion. Senior Judge HAMILTON wrote the opinion, in which Judge LUTTIG and Judge MICHAEL joined.

OPINION

HAMILTON, Senior Circuit Judge:

Richie H. Conner (Conner), the subject of an ongoing criminal tax investigation, appeals the district court's order: (1) dismissing his petitions to quash certain summonses issued by the Internal Revenue Service (IRS) to two third-party record keepers...

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