United States v. Lee, Goddard & Duffy, LLP
Opinion
Opinion
ORDER ENFORCING PETITIONER'S DEMAND THAT RESPONDENTS PRODUCE ADDITIONAL DOCUMENTS AS DIRECTED BY ORDER DATED JUNE 29, 2006
DAVID O. CARTER, District Judge.
Before the Court is Petitioner the United State's (the "IRS") Demand that Respondents Produce. Additional Documents ("Demand"). After considering the responding, supporting, and replying papers, as well as oral argument by the parties, the Court hereby GRANTS enforcement of the Demand.
I. BACKGROUND
The IRS brought an enforcement action on April 18, 2006 against Respondents Lee, Goddard & Duffy, LLP ("LGD") and William A. Goddard. The IRS is investigating LGD and Goddard for potential promoter penalties under 26 U.S.C. § § 6707 and 6708 to determine whether they are liable for penalties for failure to timely register certain tax shelters and for failing to maintain a list of investors in these tax shelters as 26 U.S.C. § § 6111 and 6112 require.
Specifically, the IRS suspects that LGD and Goddard were involved with abusive tax shelters that the accounting firm KPMG LLP ("KPMG") promoted. Documents that the IRS obtained from KPMG identified LGD and Goddard as having promoted and facilitated several potentially abusive tax…