Petition to Enforce Summons, Internal Revenue Service — United States v. Lawrence Cohen (Dkt. 1, D. Mass.)

Summary

A Petition to Enforce Internal Revenue Service Summons, Document 1, filed 02/09/24, M.B.D. No. 24-mc-94004, United States of America, Petitioner, v. Lawrence Cohen, Respondent, in the District of Massachusetts. The United States, on behalf of the Internal Revenue Service, states that Revenue Officer Seth Grossman issued a summons on September 14, 2023 directing Lawrence Cohen to appear on October 5, 2023 and produce documents and financial records for the years ended December 31, 2016, December 31, 2017, and December 31, 2018. It states that Lawrence Cohen has failed and refuses to comply. The petition asks that Lawrence Cohen be ordered to show cause why the summons should not be obeyed, and be ordered to obey it. It is signed /s/ Steven T. Sharobem, Assistant United States Attorney, dated February 9, 2024.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Cite this document

“Petition to Enforce Summons, Internal Revenue Service — United States v. Lawrence Cohen (Dkt. 1, D. Mass.).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-4-24-mc-94004-dkt-1-d-mass-b52f82d054/, SHA-256 54c2025b11ba619183860a1f0a3376e1e5d9622f97990938f940cb1515aac5f3.

Full text

Case 4:24-mc-94004 Document 1 Filed 02/09/24 Page 1 of 4

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS

)
UNITED STATES OF AMERICA, )
)
Petitioner, )
v. ) M.B.D. No. 24-mc-94004
)
LAWRENCE COHEN, )
)
Respondent. )
)

PETITION TO ENFORCE
INTERNAL REVEUE SERVICE SUMMONS

The United States of America, on behalf of its agency, the Internal Revenue Service,

and by its attorney, Joshua S. Levy, Acting United States Attorney for the District of

Massachusetts, state that:

1. This proceeding for the enforcement of an Internal Revenue Service Summons is

brought pursuant to sections 7402(b) and 7604(a) of the Internal Revenue Code of 1986, 26

U.S.C. sections 7402(b) and 7604(a).

2. Seth Grossman is a Revenue Officer of the Internal Revenue Service authorized to

issue summonses under the Internal Revenue Laws.

3. The respondent, Lawrence Cohen resides or is found at 80 Salisbury Street, Wor-

cester, Massachusetts 01609 within the jurisdiction of this Court.

4. Section 6020(b) of the Internal Revenue Code of 1986, 26 U.S.C., authorizes the

Secretary of the Treasury, acting by his agents and employees in the Internal Revenue Service, to

make a return from his own knowledge and from such information as he can obtain through

testimony or otherwise for a person who fails to file a return. For the purpose of making such a

return, Section 7602 authorizes the Secretary to issue a Summons to the person to appear at a

1
Case 4:24-mc-94004 Document 1 Filed 02/09/24 Page 2 of 4

time and place named in the Summons, to produce such books, papers, records or other data, and

to testify, as may be relevant or material to making the return.

5. On September 14, 2023, Revenue Officer Grossman issued, pursuant to Section

7602 of the Internal Revenue Code of 1986, a summons to Lawrence Cohen, directing him to

appear before Revenue Officer Grossman at the office of the Internal Revenue Service, 118

Turnpike Road, Southborough, MA 01772 at 9 A.M. on October 5, 2023 and to produce for

examination (and give testimony relating to) documents and financial records for the year(s)

ended December 31, 2016, December 31, 2017, and December 31, 2018. A copy of the

Summons is attached to this Petition as "Exhibit A". On September 14, 2023, at 1:25 P.M.,

Revenue Officer Grossman served the Summons on Lawrence Cohen by handing and attested

copy of the summons to the person to whom it was directed. Revenue Officer Grossman signed

a certification on the face of the copy of the Summons served that it is a true and correct copy of

the original.

6. Lawrence Cohen has failed and refuses to comply with the Summons.

7. The records sought by the Summons are not now in the possession of the Internal

Revenue Service, and their production by Lawrence Cohen for examination by an officer

of the Internal Revenue Service is necessary to make federal income tax returns for the year(s)

ended December 31, 2016, December 31, 2017, & December 31, 2018.

2
Case 4:24-mc-94004 Document 1 Filed 02/09/24 Page 3 of 4

WHEREFORE, the petitioners pray that:

1. Lawrence Cohen be ordered to show cause, if any he has, why he should not obey

the Summons;

2. Lawrence Cohen be ordered to obey the Summons at a time and place to be fixed

by Revenue Officer Grossman or by any other officer of the Internal Revenue Service authorized

to examine the records and take testimony; and

3. The cost of this action to be awarded to the United States.

Respectfully submitted,

JOSHUA S. LEVY
Acting United States Attorney

Dated: February 9, 2024 By: /s/ Steven T. Sharobem
STEVEN T. SHAROBEM
Assistant United States Attorney
United States Attorney’s Office
1 Courthouse Way, Suite 9200
Boston, MA 02210
(617) 748-3100
Steven.Sharobem@usdoj.gov

3
Case 4:24-mc-94004 Document 1 Filed 02/09/24 Page 4 of 4

File and source

File: 1.pdf
Size: 135,450 bytes
SHA-256: 54c2025b11ba619183860a1f0a3376e1e5d9622f97990938f940cb1515aac5f3
Our copy: 1.pdf
Original: archive.org