C1 FIRST AMENDMENT

Includes every case involving a First Amendment defense to a summons on the grounds of freedom of association, assembly, speech, or religion, and non-specific First Amendment claims.

C2 EXEMPT ORGANIZATIONS/ CHURCHES/ MINISTERS/ SECTION 7605(C)

Summonses to or involving exempt organizations, churches and ministers and their records or third-party records of their transactions; cases involving invocation and/or discussion of the Section 7605(c) restrictions on examinations; and cases rejecting the defense to a summons that the party under investigation is tax exempt.

C3 TAX PROTESTORS

Cases identifying the taxpayer as a tax protestor or involving recognized protestor tactics such as Fifth Amendment returns, excessive exemption claims, extremist constitutional and statutory claims, etc.

C4.0 FOURTH AMENDMENT - GENERAL

Cases involving non-specific Fourth Amendment or "privacy" claims and those not coded under Codes C4.1 through C4.5.

Subcoding of the approximately 275 Fourth Amendment decisions (Codes C4.0 through C4.5) is in progress but only partially completed. Until the subcoding is completed the unclassified cases will be found under Code C4.0.

C4.1 FOURTH AMENDMENT - CONSTITUTIONALITY OF SUMMONS POWER

Cases upholding the constitutionality per se of the summons statutes under the Fourth Amendment, as distinguished from Fourth Amendment objections to the summons power as applied (which are under Codes C4.0 and C4.2 through C4.5).

C4.2 FOURTH AMENDMENT - PROBABLE CAUSE FOR ISSUANCE OF SUMMONS

Cases holding that probable cause to suspect tax violations is unnecessary to issuance or enforcement of a summons. See also Code C64.2.

C4.3 FOURTH AMENDMENT - SUMMONS AS UNREASONABLE SEARCH AND SEIZURE

Cases holding that summonses and/or their enforcement do not constitute an unreasonable search and seizure. See also Codes C62 and C64.2.

C4.4 FOURTH AMENDMENT - BURDENSOMENESS/ OVERBREADTH/ VAGUENESS

Cases analyzing the contention that a summons is too burdensome, vague or overbroad. See also Code C67.

C4.5 FOURTH AMENDMENT - VICARIOUS ASSERTION

Cases refusing to permit a party to assert another's Fourth Amendment right. See also Codes C34 and C35.

C5.0 FIFTH AMENDMENT SELF-INCRIMINATION - GENERAL

Cases involving non-specific Fifth Amendment claims and those not coded under Codes C5.1 through C5.6.

Subcoding of the approximately 300 Fifth Amendment self-incrimination decisions (Codes C5.0 through C5.6) is in progress but only partially completed. Until the subcoding is completed, the unclassified cases will be found under Code C5.0.

C5.1 FIFTH AMENDMENT - CONSTITUTIONALITY OF SUMMONS POWER

Cases upholding the constitutionality per se of the summons statutes under the Fifth Amendment, as distinguished from Fifth Amendment objections to the summons power as applied (which are coded under Codes C5.0 and C5.2 through C5.6).

C5.2 SELF-INCRIMINATION - WAIVER

Cases discussing waiver of the summoned party's Fifth Amendment privilege against self-incrimination.

C5.3 SELF-INCRIMINATION - BURDEN OF PROOF/ PERSUASION

Cases discussing the burden of the party invoking the privilege against self-incrimination as a defense to the summons to demonstrate its availability.

C5.4 SELF-INCRIMINATION - IMMUNITY

Cases discussing immunity from use of evidence obtained directly or indirectly by a summons.

C5.5 SELF-INCRIMINATION - BLANKET INVOCATION

Cases forbidding a blanket plea of self-incrimination as a defense to a summons and requiring specific responses to specific demands.

C5.6 SELF-INCRIMINATION - VICARIOUS INVOCATION

Cases refusing to permit a party to assert another's Fifth Amendment privilege against self-incrimination. See also Codes C34 and C35.

C6.0 FIFTH AMENDMENT DUE PROCESS/ ABUSE OF PROCESS

Cases where enforcement of a summons is alleged to violate the Fifth Amendment due process clause or to be an abuse of the court's process; does not include all claims such as "bad faith," "harassment," "sole criminal purpose," etc. These "defenses" would involve hundreds of citations if coded separately, but are frequently discussed in cases found in this Code. Representative examples of these latter cases at all decisional levels are coded under Code C6.1.

C6.1 SOLE CRIMINAL PURPOSE/ IMPROPER PURPOSE

A representative sampling of cases dealing with the most common defense to summones issued by special agents of the Criminal Investigation Division. See also Codes C6.2 and C6.3.

C6.2 INQUIRY INTO CRIMINAL OFFENSE/ SECTION 7602(b)

Cases involving a criminal purpose inquiry under Section 7602(b).

C6.3 JUSTICE DEPARTMENT REFERRAL/ SECTION 7602(c)

Cases involving or discussing the limitation on the summons power when a Justice Department referral is in effect or has been terminated.

C7 OTHER CONSTITUTIONAL OBJECTIONS

Cases involving unspecified constitutional objections and all constitutional objections other than the First, Fourth and Fifth Amendments, which are separately coded.

C8.0 SCOPE OF SUMMONS POWER/ SECTION 7602

Cases discussing the breadth of the summons power generally and its liberal interpretation.

C8.1 SCOPE OF SUMMONS POWER/ GRAND JURY ANALOGY

Cases comparing the summons to a grand jury subpoena and the investigative authority of the Secretary to that of a grand jury.

C8.2 DUTY TO CANVASS AND INQUIRE/ SECTION 7601

Cases discussing the Secretary's duty "to proceed, from time to time, through each internal revenue district and inquire after and concerning all persons therein who may be liable to pay any internal revenue tax, and all persons owning or having the care and management of any objects with respect to which any tax is imposed."

C9 ADMINISTRATIVE PROCEDURE ACT

Cases discussing some aspect of the Administrative Procedure Act (5 U.S.C. Sections 551 - 559, 701 - 706, 1305, 3105, 3344, 4301, 5335, 5362, 7521) and the summons power.

C10 BANK SECRECY ACT

Cases discussing some aspect of the Bank Secrecy Act (12 U.S.C. Sections 1730d, 1829b, 1951 - 1959; 31 U.S.C. Sections 1051 - 1062, 1081 - 1083, 1101 - 1105, 1121, 1122; and Part 103, Title 31, C.F.R.) and the summons power.

C11 FAIR CREDIT REPORTING ACT

Cases discussing some aspect of the Fair Credit Reporting Act (15 U.S.C. Sections 1681 - 1681t) and the summons power.

C12 RIGHT TO FINANCIAL PRIVACY ACT/ PRIVACY ACT/ SECTION 7852(e)

Cases discussing some aspect of the Right to Financial Privacy Act (12 U.S.C. Sections 3401 - 3422) or the Privacy Act (5 U.S.C. Section 552a) and the summons power. See also Codes C28 and C30.

C13 FREEDOM OF INFORMATION ACT

Cases discussing some aspect of the Freedom of Information Act (5 U.S.C. Section 552) and the summons power.

C14.0 FEDERAL RULES OF CIVIL PROCEDURE

Cases discussing some application or non-application of the Federal Rules of Civil Procedure to summons enforcement, other than the discovery rules (Rules 26 through 37) which are coded under Code C37.0.

C14.1 ADEQUACY OF PLEADINGS

Cases discussing the adequacy of the Government's summons enforcement pleadings; cases discussing the adequacy of an opponent's submissions. See also Code C40.

C14.2 EVIDENCE QUESTIONS/ FEDERAL RULES OF EVIDENCE

Cases raising some rule of evidence in objection to compliance with a summons other than cases coded under Codes C4, C5, C19, C20, C21, C37.1, c38.0, C41, C51.0 and C72; cases discussing some application of a rule of evidence to the summons power.

C15 STATUTES OF LIMITATIONS/ LACHES; DEFENSE OF

Cases rejecting the defense that the summons is invalid because the statute of limitations on assessment, collection or prosecution has run; cases rejecting the defense that the Government took too long to commence a summons enforcement proceeding.

C16 OTHER STATUTORY OBJECTIONS

Cases treating with all statutory objections and defenses, state and federal, not otherwise specifically coded.

C17 STATUTES OF LIMITATIONS; TOLLING OF/ SECTION 7609(e)/ SECTION 982(e)

Cases dealing with the suspension of the civil and criminal statutes of limitations with respect to actions against a taxpayer.

C18.0 POSSESSION/ CUSTODY/ CONTROL/ OWNERSHIP

Cases dealing with the taxpayer's or other summoned party's relationship to the summoned records; attempts to shield records through changes in possession, custody or control; identification of the proper summoned party. See also Codes C4.5, C5.6, C34 and C35.

C18.1 LOST OR DESTROYED RECORDS

Cases involving non-compliance because of the loss or destruction of records. See also Code C57.

C19 ACCOUNTANT-CLIENT PRIVILEGE

Cases rejecting the accountant- client privilege as a defense to a summons.

C20 ATTORNEY-CLIENT PRIVILEGE/ WORK PRODUCT DOCTRINE

All cases where the attorney- client privilege and/or the attorney work product doctrine has been asserted as a defense to a summons; and cases discussing all elements of the attorney-client privilege, burden of proof, applicability to tax investigations, etc.

C21 OTHER STATE PRIVILEGES

Cases rejecting all the various non-common law evidentiary privileges as defenses to a summons, including the physician-patient privilege, the priest-penitent privilege, the banker-depositor privilege, a stenographer-dictator privilege, etc.

C22 ACCOUNTING WORKPAPERS

Cases discussing the amenability of accounting workpapers to the summons power and describing the various types of accounting workpapers which have been successfully summoned other than the workpapers described in Code C23.

C23 TAX POOL ANALYSES/ INTERNAL AUDIT DOCUMENTS/ AUDIT PROGRAMS

A subgroup of accounting workpapers which are sensitive in nature and produced only reluctantly. In addition to the above descriptions, they are known by various other names. Audit programs are also known as audit workplans or checklists. Internal audit documents may be known as "bluebacks" and reports or letters to management. Tax pool analyses are also known as tax reserve memoranda or reports, tax contingency memoranda or reports, and contingent tax liability analyses.

C24 SECTION 7609 - GENERAL

Cases involving general principles of Section 7609, its purposes and construction in a summons enforcement case; any substantive discussion of Section 7609 not falling within Codes C17 or C24 through C33, such as notice, noticees, time limitations, stays of compliance, intervention, etc.

C25 SECTION 7609 - ACCOUNTANTS

Cases specifically involving an interpretation or analysis of accountants as statutory third-party recordkeepers.

C26 SECTION 7609 - ATTORNEYS

Cases specifically involving an interpretation or analysis of attorneys as statutory third-party recordkeepers.

C27 SECTION 7609 - BROKERS

Cases specifically involving an interpretation or analysis of brokers as statutory third-party recordkeepers.

C28 SECTION 7609 - CONSUMER REPORTING AGENCIES

Cases specifically involving an interpretation or analysis of consumer reporting agencies as statutory third-party recordkeepers. See also Codes C11 and C12.

C29 SECTION 7609 - CREDIT CARD ISSUERS

Cases specifically involving an interpretation or analysis of credit card issuers as statutory third-party recordkeepers; summonses for credit cards and credit card data.

C30.0 SECTION 7609 - FINANCIAL INSTITUTIONS

Cases specifically involving an interpretation or analysis of financial institutions as statutory third-party recordkeepers. See also Code C12.

C30.1 SECTION 7609 - BARTER EXCHANGES

Cases specifically involving an interpretation or analysis of barter or trade exchanges as statutory third-party recordkeepers.

C31 JOHN DOE SUMMONSES/ SECTION 7609(f)

Cases interpreting the statutory and pre-statutory (pre-1977) requirements for issuance of a summons which does not identify the particular taxpayer(s) under examination; also includes cases where records of unknown taxpayers are required in order to investigate a known summoned party such as a return preparer. See also Code C68.

C32 EMERGENCY SUMMONSES/ SECTION 7609(g)

Cases involving the issuance of no-notice summonses where notice might result in any of the consequences enumerated in Section 7609(g).

C33 COLLECTION SUMMONSES/ SECTION 7609(c)(2)

Cases involving the use of the summons for the purpose of collecting unpaid taxes; cases involving no-notice summonses issued pursuant to Section 7609(c)(2).

C34 STANDING TO INTERVENE

Cases involving the principles of intervention in summons cases prior to enactment of Section 7609; cases specifically discussing Section 7609 requirements for intervention by parties where not plainly mandated by the statute; cases involving attempts at non-Section 7609 (permissive) intervention after enactment of the statute; cases involving intervention by summoned parties in proceedings to quash by taxpayers.

C35 STANDING TO DEFEND

Cases discussing the legal elements necessary to successfully assert specific defenses to a summons, including "standing," "possessory or protectible interest," and privileged relationships.

C36.0 DUAL REPRESENTATION/ CONFLICT OF INTERESTS

Cases dealing with attempts by the taxpayer's attorney to represent summoned witnesses and third parties with actually or potentially conflicting interests. See also Code C36.1.

C36.1 ATTEMPTS TO MONITOR THE INVESTIGATION

Attempts by the taxpayer or his attorney to be present when third parties respond to summonses, or to acquire copies of documents produced by or transcripts taken of the testimony of third-party witnesses. See also Codes C37 and C38.

C37.0 DISCOVERY/ RESTRICTIONS ON DISCOVERY

Cases involving attempts by the taxpayer or other party to obtain pretrial discovery of the Government's investigation through depositions, answers to interrogatories, requests for admissions, motions to produce, trial subpoenas, etc.; and cases involving the occasional use of discovery by the Government in a summons enforcement case. See also Code C38.

C37.1 INVESTIGATIVE FILE PRIVILEGE

Cases where the Government resists discovery of its files on the basis of the investigative files or governmental privilege. See also Code C38.0.

C38.0 INFORMANTS/ INFORMANT PRIVILEGE

Cases involving attempts to discover whether the investigation involves an informant or to discover an informant's identity; invocation of the informant privilege; legal implications of the fact of an informant in the case. See also Code C37.1.

C38.1 IN CAMERA EXAMINATIONS

Cases where the court conducted or was urged to conduct an in camera examination, either of the Government's file or of the summoned data. See also Code C37.

C39.0 SECOND INSPECTION/ UNNECESSARY EXAMINATION/ SECTION 7605(b)

Cases involving claims that the Government has made one examination of documents (actually or derivatively) and is therefore prohibited from making a second examination; cases where, for this or other reasons, the examination is claimed to be unnecessary (i.e., the statute of limitations has run, the taxpayer is not liable for taxes, etc.). See also Codes C39.1, C39.2.

C39.1 RETAINED COPIES OF RECORDS FILED WITH THE GOVERNMENT/ DOCUMENTS ALREADY IN GOVERNMENT'S POSSESSION

Cases involving summonses for an employer's retained copies of Forms W-4, or a taxpayer's or accountant's retained copies of returns, or a bank's or broker's retained copies of Forms 1099, the originals of all of which have been provided to the Internal Revenue Service. See also Code C51.

C39.2 INFORMATION ALREADY IN POSSESSION OF GOVERNMENT

Cases not coded under Codes C39.0 and C39.1 involving the contention that summoned data or information, having been examined once or being available from other sources, is in the "possession" of the IRS.

C40 NECESSITY FOR HEARING/ SUMMARY JUDGMENT/ SECTION 7609(h)(2)

Cases analyzing the situations where courts have permitted, required, rejected or limited evidentiary hearings in summons cases; cases analyzing when and under what conditions a party will be entitled to a hearing; cases involving enforcement by default, summary judgment or judgment on the pleadings; cases stating that summonses should be swiftly adjudicated.

C41 FORENSIC PURPOSES/ ORIGINAL RECORDS

Cases involving the use of a summons to obtain original documents for laboratory, comparison, evidentiary or analytical purposes, even though the underlying information or copies of documents may already be in the Government's possession; cases involving the Government's right to have originals rather than copies or to have data in the form demanded rather than in the form urged by the summoned party. See also Codes C39.1 and C39.2.

C42 RIGHT TO COPY/ RETURN OF RECORDS

Cases involving the right of the Internal Revenue Service to retain and copy summoned records; the duty to return summoned records to the source; the time and circumstances of the return of summoned records. See also Code C62.

C43.0 VIOLATION OF INTERNAL PROCEDURES/ GOVERNMENT MISCONDUCT/ IMPROPER DISCLOSURE/ SECTIONS 6103, 7213, 7217

Cases where alleged violations of the Internal Revenue Service Manual or other internal guidelines or procedures, or other misconduct (such as improper disclosure of return information in violation of Section 6103) are urged as a defense to the summons or the investigation. See also Code C44.

C43.1 PRESUMPTIONS OF GOVERNMENTAL REGULARITY, INTEGRITY AND GOOD FAITH

Cases holding that there is a presumption of regularity, integrity and/or good faith attaching to the official acts of Government officers which precludes the court from assuming otherwise in the absence of specific factual allegations to the contrary.

C44 PARALLEL INVESTIGATION/ STRIKE FORCE INVOLVEMENT

Cases involving enforcement of a summons where there is a pending, unrelated investigation by another agency; cases involving Internal Revenue Service investigations under the aegis or sponsorship of an organized crime strike force. See also Codes C43.0, C43.1.

C45.0 COSTS OF COMPLIANCE/ SECTION 7610

Cases dealing with the reimbursement of costs incurred in complying with a summons or enforcement order.

This Code will appear as C45 until subcoding of Codes C45.0 and C45.1 is completed.

C45.1 LIABILITY FOR COMPLIANCE/ SECRETARY'S CERTIFICATE/ SECTIONS 7609(i)(2), (3)

Cases treating with a summoned party's immunity from a taxpayer's suit for complying with a summons or enforcement order; cases interpreting the effect of the Secretary's certificate under Section 7609(i)(2). See also Code C63.

Cases in this subcode will be found under Code C45 until subcoding is completed.

C46 COSTS OF SUIT/ ATTORNEY'S FEES/ SECTION 7430

Cases dealing with the imposition of costs in a summons enforcement suit, including attorney's fees. See also Code C57.

C47 TAX TREATY SUMMONSES/ SECTION 7852(d)

Cases dealing with summonses issued in furtherance of tax treaty requests by foreign governments; cases involving U.S. invocation of tax treaties to obtain foreign data. See also Code C72.

C48 FOREIGN RECORDS/ FOREIGN LAW/ SECTION 982(b)(2)

Summons cases where foreign law restrictions on disclosure are raised as a defense; summons cases raising issues of foreign law. See also Code C72.

C49 IMPROPER PAYMENTS/ SLUSH FUNDS/ KICKBACKS/ EVEVEN QUESTIONS

Summons cases involving multinational corporate bribes, kickbacks, slush funds, political contributions, internal investigations, and the " Eleven" (or Five) Questions program.

C50 TIME AND PLACE OF EXAMINATION/ SECTION 7605(a)/ SECTION 7605(a)/ SECTION 7609(i)(1)

Cases dealing with the question of proper times, places and conditions of compliance with the summons or enforcement order.

C51.0 RELEVANCE/ MATERIALITY

Cases dealing with the requirement that the summoned data be relevant to the investigation, and that the Government demonstrate that fact as part of its prima facie case; cases dealing with the defense that the summoned data are not relevant or material to the investigation.

C51.1 RECORDS OUTSIDE THE YEARS UNDER INVESTIGATION

Cases involving summonses for books and records of transactions before and after the taxable period(s) under investigation. See also Code C51.2.

C51.2 METHODS OF PROOF/ NET WORTH AND EXPENDITURES/ BANK DEPOSITS/ SPECIFIC ITEMS/ SOURCE AND APPLICATION

Cases discussing various direct and indirect methods of reconstructing income as they pertain to summons enforcement. See also Code C51.1.

C52 REQUIRED RECORDS/ SECTION 6001

Cases dealing with the Government's right to require the maintenance and production of various records and the effect of personal defenses raised to bar a summons for such legally required records.

C53 RES JUDICATA/ COLLATERAL ESTOPPEL/ ISSUE PRECLUSION

Cases dealing with the effect of previously litigated issues and defenses by the same or a related party.

C54 TIME OF ISSUANCE/ SUBSEQUENT EVENTS

Cases dealing with the time at which the summons is tested when events subsequent to its issuance are raised as a defense to compliance. See also Code C6.3.

C55 MAGISTRATES/ COMMISSIONERS

All summons cases referred to or considered or decided by a Magistrate (previously a Commissioner); cases discussing or analyzing the jurisdiction and authority of a Magistrate to hear or decide summons enforcement cases; cases dealing with appellate jurisdiction over summons enforcement decisions and orders by Magistrates.

C56 SERVICE OF PROCESS/ IN PERSONAM JURISDICTION/ VENUE/ SECTION 7603/ SECTION 7701(a)(39)

Cases dealing with proper service of the summons, proper venue, proper service of judicial process in an enforcement action, and the obtaining of personal jurisdiction over a summoned party.

C57 CONTEMPT/ SECTION 7604(b)

All cases dealing with contempt of the summons, contempt of court (civil and criminal), body attachments, bench warrants, and writs of arrest, where the summons or judicial enforcement order is disobeyed or defeated. See also Codes C18.1, C46, C64.3 and C64.4.

C58.0 NO STAY PENDING APPEAL

Cases denying stays of summons enforcement orders pending appeal.

C58.1 MOOTNESS

Cases discussing mootness in appeals from summons enforcement orders where the summoned party has complied in whole or part.

C58.2 STAYS PENDING APPEAL

Cases where stays pending appeal have been entered.

C59.0 SUMMONS MODIFIED/ EXPANDED/ RESTRICTED

All cases ordering enforcement of a summons by requiring production of more, less, or different data than those sought in the summons.

C59.1 NUNC PRO TUNC ORDERS

Cases where the court has occasion to enter or discuss retroactively effective orders.

C59.2 USE RESTRICTIONS

Cases where a party has sought to limit the summoned data to a particular use or type of use, such as, for example, use in a civil proceeding only, or use only against a particular party to the exclusion of others. See also Codes C5.4 and C62.

C60 ENFORCEMENT DENIED

All cases denying enforcement of a summons in its entirety, for whatever reason.

C61.0 INJUNCTIVE RELIEF

Non-enforcement cases seeking to enjoin compliance with a summons, or to quash it, or to restrain the investigation in which it was issued; cases in which the Government has sought injunctive relief in connection with, in addition to, or in lieu of a summons.

C61.1 PROCEEDINGS TO QUASH/ SECTION 7609(b)(2)/ SECTION 982(a)(2)

Cases involving statutory proceedings to quash summonses and formal document requests. See also Code C34.

C62 SUPPRESSION RELIEF

Cases seeking to suppress the fruits of a summons or to obtain the return of summoned data. See also Codes C4.0 through C4.5 and C42.

C63 TORT SUITS/ DAMAGES

Tort suits by taxpayers seeking damages for issuance of or compliance with a summons or the use of summoned data. See also Code C45.1.

C64.0 CRIMINAL CASES - GENERAL

Criminal cases involving some application or interpretation of summons enforcement law and not coded under Codes C64.1 through C64.4.

C64.1 CRIMINAL CASES - FEDERAL RULES OF CRIMINAL PROCEDURE

Cases involving both the summons power and some (not necessarily related) application or discussion of the Federal Rules of Criminal Procedure.

C64.2 CRIMINAL CASES - SEARCH WARRANTS

Cases involving the summons power and the use of a search warrant. See also Code C66.

C64.3 CRIMINAL CASES - SECTION 7203

Cases discussing or involving prosecution under Section 7203 for failure to comply with a summons; and summonses used to investigate violations of Section 7203. See also Code C57.

C64.4 CRIMINAL CASES - SECTION 7210

Cases discussing or involving prosecution under Section 7210 for failure to comply with a summons. See also Code C57.

C65 RIGHT TO JURY

Cases denying the right to a jury in summons enforcement cases and ancillary contempt proceedings.

C66 TELEPHONE COMPANY/ TOLL RECORDS/ SUBSCRIBER RECORDS/ PEN REGISTERS/ ELECTRONIC SURVEILLANCE

Cases involving summonses for telephone company records; summons cases involving pen registers and electronic surveillance. See also Code C29.

C67 RECITATION OF SUMMONS DUCES TECUM PROVISIONS

Cases containing verbatim recitations of the duces tecum provisions of the summons involved; classified for comparison purposes in order to illustrate the various types of records and data obtainable by summons. See also Code C51.

C68 SPECIFIC COLLATERAL PURPOSE/ RESEARCH/ TAXPAYER COMPLIANCE MEASUREMENT PROGRAM (TCMP)

Cases involving a specifically identified purpose of the summons other than those recited in Section 7602 of the Code, including "research" summonses and TCMP summonses. See also Code C31.

C69 LEGISLATIVE HISTORY OF SUMMONS PROVISIONS

Cases analyzing, discussing or citing the legislative history of any of the summons statutes.

C70 TECHNICAL DEFECTS/FORM OVER SUBSTANCE/ MINISTERIAL ERRORS

Cases holding that minor administrative or procedural errors in the issuance and service of summonses which do not affect the substantive rights of parties do not render such summonses unenforceable.

C71 TAX SHELTERS

Summons cases involving abusive tax shelters and their promoters. See also Code C31.

C72 FORMAL DOCUMENT REQUESTS/ SECTION 982

Cases involving formal requests for foreign-based documentation and its admissibility in evidence. See also Codes C14.2, C56 and C61.1.