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MOLLISON v. U.S.

Docket Nos. 06-1539-cv(L), 06-1542-cv(Con), 06-1545-cv(Con), 06-1550-cv(Con), 06-1551-cv(Con), 06-1553-cv(Con), 06-1554-cv(Con), 06-1555-cv(Con), 05-1557-cv(Con).

481 F.3d 119 (2007)

Nicole Vento MOLLISON, VIFX, LLC, As Successor in Interest to DTDV, Nicole Vento, Gail Vento, Renee Vento, VI Derivatives, LLC, Richard Vento, Lana Vento, Richard & Lana Vento 2000 Dynasty Trust, Petitioners-Appellants, v. UNITED STATES of America, Respondent-Appellee.

United States Court of Appeals, Second Circuit.

Decided: March 16, 2007.

Attorney(s) appearing for the Case

Joseph M. Erwin (Steven M. Nachman, on the brief), Dallas, TX, for Petitioners-Appellants.

Sarah E. Light, Assistant United States Attorney (Michael J. Garcia, United States Attorney, Southern District of New York, Sean H. Lane, Assistant United States Attorney, on the brief), New York, NY, for Respondent-Appellee.

Before WINTER, WALKER, and STRAUB, Circuit Judges.

PER CURIAM.

Petitioners-Appellants, who consist of members of the Vento family and their associated entities, seek to quash a third-party summons issued by the Internal Revenue Service ("IRS") to Salomon Smith Barney, Inc. as part of an investigation into potential tax liabilities arising from the sale of stock worth approximately $180 million. In dismissing the petitions and enforcing the summons, the District Court for the Southern District of New York (Jed S. Rakoff...

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