United States of America, Etc. v. James R. Coson, Etc.

The Internal Revenue Service wants to inspect a mass of business records for several years of thirteen corporations apparently dominated by Coson. On a request to enforce a massive summons, the district court has ordered compliance. Thus, we have an appeal.

With the gracefulness of an elephant, the Internal Revenue Service has given Coson a lot to complain about. But we find the complaints mostly beyond our reach.

Early in January 1973, Coson was served with 157 summonses for books' and records, apparently one for each of several years for each of several corporations. Coson appeared but demanded witness fees and mileage on each summons. And possibly he was right. So the first set went awry. The Service, without regard for the number of trees required to produce the pulp to produce the paper, then got out another group of summonses, again about as massive as the first set, requiring attendance on another day. This group was withdrawn.

Finally, round three arrived. The Service issued one comprehensive summons. The summons day arrived. Co-son appeared, but declined cooperation until paid alternately $260.00 plus mileage or $8,840.00 plus mileage for the government’s…