District court's denial of defendants' motion to quash administrative summonses issued by the IRS related to an investigation into possible improper tax shelters is affirmed where: 1) the summonses are not overly broad; 2) the summonses were not issued for an improper purpose; 3) defendants' claim that the IRS is already in possession of the summoned documents fails; and 4) defendants' remaining claims are rejected.
Appeal from the United States District Court for the District of Massachusetts
Decided October 7, 2009
Opinion by Howard, Circuit Judge
For Appellee: Rachel I. Wollitzer, Attorney, Tax Division, Department of Justice, Michael J. Sullivan, United States Attorney, John A. DiCicco, Acting Assistant Attorney General, Gilbert S. Rothenberg, Acting Deputy Assistant Attorney General and Robert W. Metzler, Attorney, Tax Division, Department of Justice