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GAETANO v. UNITED STATES

No. 20-1902.

994 F.3d 501 (2021)

Kimberly Basehart GAETANO; Richard Gaetano, Petitioners-Appellants, v. UNITED STATES of America, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided and Filed: April 9, 2021.

Attorney(s) appearing for the Case

ON BRIEF: Joseph Falcone , JOSEPH FALCONE, P.C., Southfield, Michigan, for Appellants. Elissa Hart-Mahan , Joan I. Oppenheimer , DEPARTMENT OF JUSTICE, Washington, D.C., for Appellee.

Before: GUY, DONALD, and MURPHY, Circuit Judges.

OPINION

The Internal Revenue Service (IRS) issued a summons to a point-of-sale systems provider, seeking records related to Richard and Kimberly Gaetano and their cannabis businesses. Alleging the summons was issued in bad faith, the Gaetanos brought this action to quash the summons under 26 U.S.C. §...

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