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U.S. v. MONUMENTAL LIFE INS. CO.

No. 05-5080.

440 F.3d 729 (2006)

UNITED STATES of America, Plaintiff-Appellee, v. MONUMENTAL LIFE INSURANCE COMPANY, Defendant-Appellant.

United States Court of Appeals, Sixth Circuit.

Decided and Filed: March 3, 2006.

Attorney(s) appearing for the Case

ARGUED: Kevin L. Smith, Hines, Smith LLP, Costa Mesa, California, for Appellant.

John A. Dudeck, Jr., United States Department of Justice, Washington, D.C., for Appellee.

ON BRIEF: Kevin L. Smith, Hines, Smith LLP, Costa Mesa, California, David B. Tachau, Kevin M. Norris, Tachau, Maddox, Hovious & Dickens, Louisville, Kentucky, for Appellant.

John A. Dudeck, Jr., Frank P. Cihlar, United States Department of Justice, Washington, D.C., for Appellee.

Before: MERRITT, MARTIN, and GILMAN, Circuit Judges.

OPINION

RONALD LEE GILMAN, Circuit Judge.

Monumental Life Insurance Company appeals from the district court's order enforcing an administrative summons issued by the Internal Revenue Service (IRS). The summons requested voluminous documents from Monumental, a third party in the IRS's investigation of Johnson Systems, Inc. On appeal, Monumental argues that the district court erred in rejecting the magistrate judge's findings that (1) the IRS already had in...

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