United States v. Abrahams

905 F.2d 1276 66 A.F.T.R.2d 90 -5125, 90-1 USTC P 50,310 , 30 Fed. R. Evid. Serv. 570 UNITED STATES of America; Darrell G. Henderson, Special Agent, Internal Revenue Service, Petitioner/Appellee-Cross-Appellant, v. Charles L. ABRAHAMS, Respondent/Appellant-Cross-Appellee. Nos. 88-5901, 88-5653. United States Court of Appeals, Ninth Circuit. Argued and Submitted Nov. 1, 1989. Decided June 8, 1990. William S. Rose, Jr., Gary R. Allen, Charles E. Brookhart, and John A. Dudeck, Jr., Tax Div., U.S. Dept. of Justice, Washington, D.C., for petitioner/appellee-cross-appellant. Charles L. Abrahams, La Mesa, Cal., in pro per. Appeal from the United States District Court for the Southern District of California. Before HUG, CANBY, and BOOCHEVER, Circuit Judges. CANBY, Circuit Judge: 1 The United States appeals from an order of the district court granting limited enforcement of a summons issued by the Internal Revenue Service. Charles Abrahams, the summonee, cross appeals. We affirm in part, vacate in part, and remand. I. FACTS 2 Abrahams is an attorney who prepares income tax returns for his clients, and also represents many of them in disputes with the Internal Revenue Service before the Tax…