In Re Sells

719 F.2d 985 83-2 USTC P 9662 In re Grand Jury Investigation, Peter A. SELLS, et al. SELLS, INC., a California corporation, commonly known as Sells Engineering Company, Inc., Peter A. Sells, Fred R. Witte, Center Glass Co. No. 3, and B & W Investments, Appellants, v. UNITED STATES of America, Appellee. No. 80-5829. United States Court of Appeals, Ninth Circuit. Argued and Submitted March 3, 1982. Submission Withdrawn July 16, 1982. Resubmitted Sept. 21, 1983. Decided Nov. 1, 1983. Arlington Ray Robbins, Shenas, Robbins, Shenas & Shaw, San Diego, Cal., for appellants. Robert E. Lindsay, William A. Whitledge, Washington, D.C., for appellee. Appeal from the United States District Court for the Southern District of California. Before WRIGHT, SNEED and ALARCON, Circuit Judges. SNEED, Circuit Judge: 1 This appeal is from an order of the district court granting the Internal Revenue Service (IRS) access to specified grand jury materials pursuant to Rule 6(e)(3)(C)(i) of the Federal Rules of Criminal Procedure. The IRS sought the documents to facilitate a determination of appellants' civil tax liability for the years 1972 and 1973. We heard oral argument on March 3, 1982, but…