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UNITED STATES v. COATES

Civ. No. S-80-603 MLS.

526 F.Supp. 248 (1981)

UNITED STATES of America and Charles W. Brown, Revenue Agent, Petitioners, v. Edwin R. COATES, as Representative of Church of Reflection, Inc., Respondent.

United States District Court, E. D. California.

November 19, 1981.

Attorney(s) appearing for the Case

Michael H. C. Chun, Trial Atty., Tax Division U. S. Dept. of Justice, Washington, D. C., for petitioners.

John M. Youngquist, San Francisco, Cal., for respondent.

OPINION

MILTON L. SCHWARTZ, District Judge.

The tax investigation giving rise to this action to enforce an Internal Revenue Service ("IRS") summons commenced sometime prior to December 1, 1978. On that date the IRS District Director, by letter, requested respondent Edwin R. Coates, as representative of the Church of Reflection, Inc. ("Church"), to provide the IRS with the following items: 1) a copy of the annual financial reports of the Church for the years...

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