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U.S. v. SIDEMAN & BANCROFT, LLP

No. 11-15930.

704 F.3d 1197 (2013)

UNITED STATES of America, Plaintiff-Appellee, v. SIDEMAN & BANCROFT, LLP, Defendant-Appellant.

United States Court of Appeals, Ninth Circuit.

Filed January 8, 2013.

Attorney(s) appearing for the Case

Jay R. Weill (argued), Sideman & Bancroft LLP, San Francisco, CA, for Appellant.

Tamara W. Ashford , Deputy Assistant Attorney General, Washington, D.C.; Michael J. Haungs (argued) and John A. Dudeck, Jr. , United States Department of Justice, Tax Division, Washington, D.C., for Appellee.

Before: J. CLIFFORD WALLACE, SUSAN P. GRABER, and MARSHA S. BERZON, Circuit Judges.

OPINION

WALLACE, Circuit Judge:

Sideman & Bancroft, LLP (Sideman) appeals from the district court's order enforcing an Internal Revenue Service (IRS) administrative summons. We have jurisdiction under 28 U.S.C. § 1291, and we affirm.

I.

The IRS is currently undertaking a criminal investigation of Mary Nolan to determine whether she attempted to evade or defeat her tax liabilities or made a false declaration under penalty of perjury...

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