Ronald Williams v. Robert Kunze, Irs Agent

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• explaining that a warrant authorizing seizure of all of a company’s records would be lawful when “probable cause exists to believe that an entire business was merely a scheme to defraud, or that all records of a business are likely to constitute evidence”
• rejecting particularity challenge to a seizure of 50,000 to 60,000 documents, over 90% of which were client files, because the warrant “specifically authorized” the seizure of those documents
• explaining that a warrant authorizing seizure of all of a company’s records would be lawful when “probable cause exists to believe that an entire business was merely a scheme to defraud, or that all records of a business are likely to constitute evidence”
• rejecting particularity challenge to a seizure of 50,000 to 60,000 documents, over 90% of which were client files, because the warrant “specifically authorized” the seizure of those documents
• rejecting argument that authority to seize all client files of tax consultant was overbroad because probable cause supported widespread fraud involving offshore tax shelters and even files relating to onshore transactions that may provide relevant evidence
• rejecting argument that authority to seize all client files of tax consultant was overbroad because probable cause supported widespread fraud involving offshore tax shelters and even files relating to onshore transactions that may provide relevant evidence

Source: CourtListener parenthetical corpus (CC0).