Emory W. Speck Mary F. Speck Speck Cab Co., Inc., Dba Veteran's Taxicab Co. v. United States
Opinion
Opinion
Goodwin, J.
Pursuant to an investigation into possible tax evasion by taxpayers Mary F. Speck and her son Emory W. Speck, the Internal Revenue Service (IRS) contacted present and former employees of the Specks through the use of circular letters. The Specks filed in the district court a motion styled as a motion to quash summonses. The district court denied their motion. The Specks appeal, and we affirm.
BACKGROUND
The Specks operate a taxicab business and keep their own business records. In 1992, the IRS received information that the Specks were receiving so called “back-book” income without reporting it as business income on the company records. In the taxicab busi ness, “back-book” income is money paid by taxicab drivers to their employer when the drivers fail to work a regularly scheduled shift.
On January 7, 1993, the IRS executed a warrant to seize records of “back-book” income from the Specks. The seized records covered only a four-week period and were, the IRS believed, incomplete. To reconstruct the income resulting from all “back-book” payments, Special Agent Lessler, the IRS Agent assigned to the investigation, drafted a letter that he sent to all present and past drivers for…