Vanderhoof
Vanderhoof v. Commissioner of the Internal Revenue Service
Opinion
Opinion
Ishii, J.
MEMORANDUM OPINION AND ORDER DENYING PLAINTIFF’S MOTION TO QUASH SUMMONS AND DENYING WITHOUT PREJUDICE DEFENDANT’S MOTION FOR SUMMARY ENFORCEMENT OF SUMMONS [Docs. 1,11, 23]
Plaintiff Margaret Vanderhoof (“Van-derhoof’) challenges the validity of twelve summonses issued by defendant Commissioner of the Internal Revenue Service (“IRS”) to third parties who allegedly possess records of Vanderhoofs investment income for the tax years 1996 and 1997. The IRS requests an order summarily enforcing the summons.
The court has jurisdiction over this proceeding. 26 U.S.C. § 7609 (h)(1).
PROCEDURAL AND FACTUAL BACKGROUND
IRS agent Calvin was assigned to investigate the' income tax liabilities of Robert and Margaret Vanderhoof for the tax years of 1996 and 1997. Twelve summonses were issued pursuant to 26 U.S.C. § 7602 on October 21, 1998 to third party record keepers whom the IRS believes may have information and/or records pertaining to assets of the Vanderhoofs, that in turn may be relevant to an IRS investigation concerning the Vanderhoofs’ federal tax liabilities for the tax years 1996 and 1997. The eleven third-party record keepers who received summonses are: Dean Witter Reynolds,…