REISERER v. U.S.

No. 05-35615.

479 F.3d 1160 (2007)

Kenneth H. REISERER; Reiserer & Agee LLP, by Kenneth H. Reiserer, its successor in interest, Petitioners-Appellants, v. UNITED STATES of America, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Filed March 20, 2007.


Attorney(s) appearing for the Case

John M. Colvin, Chicoine & Hallett, P.S., Seattle, WA, for the appellants.

Gretchen M. Wolfinger, Tax Division, U.S. Department of Justice, Washington, D.C., for the appellee.

Before B. FLETCHER and McKEOWN, Circuit Judges, and WILLIAM W. SCHWARZER, District Judge.


SCHWARZER, District Judge.

The Estate of Kenneth Reiserer and the law firm Reiserer & Agee LLP (collectively, Reiserer) appeal the denial of their motion to quash an Internal Revenue Service (IRS) summons issued to the Bank of America. The IRS issued the summons in connection with its investigation to determine whether penalties should be imposed on Reiserer pursuant to 26 U.S.C. §§ 6700 and 6701 for promoting an abusive tax shelter. The district court...

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