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U.S. v. BERNHOFT

Case No. 08-C-0515.

666 F.Supp.2d 943 (2009)

UNITED STATES of America, Petitioner, v. Robert BERNHOFT, Respondent.

United States District Court, E.D. Wisconsin.

As Corrected November 17, 2009.

Attorney(s) appearing for the Case

Robert E. Fay, United States Department of Justice, Washington, DC, for Petitioner.

Robert E. Barnes, The Law Office of Robert G. Bernhoft SC, Milwaukee, WI, for Respondent.

DECISION AND ORDER

RUDOLPH T. RANDA, District Judge.

BACKGROUND

On June 13, 2008, the Petitioner, the United States of America ("the Government"), filed a petition to enforce an Internal Revenue Service ("IRS") administrative summons against the Respondent, Robert Bernhoft ("Bernhoft"). The summons was issued pursuant to 26 U.S.C. § 7602 in connection with an IRS investigation into whether Joseph Banister ("Banister")—an independent...

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