United States v. Coates

692 F.2d 629 82-2 USTC P 9674 UNITED STATES of America and Charles W. Brown, Revenue Agent, Appellants/Cross-Appellees, v. Edwin R. COATES, as Representative of Church of Reflection, Inc., Appellee/Cross-Appellant. Nos. 82-4013, 82-4025. United States Court of Appeals, Ninth Circuit. Argued and Submitted Sept. 13, 1982. Decided Nov. 18, 1982. Dan Ross, Tax Division, Dept. of Justice, Washington, D.C., for U.S.A. John M. Youngquist, San Francisco, Cal., for Coates. Appeal from the United States District Court for the Eastern District of California. Before BROWNING, PREGERSON and POOLE, Circuit Judges. PREGERSON, Circuit Judge: 1 The Internal Revenue Service (IRS) brought an action in the district court, 526 F.Supp. 248 , to enforce an IRS summons for production of financial, corporate, and religious records of the Church of Reflection, Inc. (Church). The summons 1 was directed to Edwin Coates, as representative of the Church, for the purpose of investigating the Church's qualification for tax exempt status. By the time the final district court determination was made, only two of the items sought by the summons remained in dispute--the books of account and the corporate minute books…