U.S. Appellate Court Affirms Summons under French Treaty

On February 5, 2001, the U.S. Court of Appeals for the Ninth Circuit issued an opinion affirming the decision of the U.S. District Court’s dismissing summary judgment of French taxpayer’s complaint to quash an Internal Revenue Service (I.R.S.) summons issued at the request of French tax authorities under Article 27 of the French-U.S. double tax treaty. The suit was brought by David and Liliane Chelala, French nationals who permanently reside in the Congo and are the sole ultimate shareholders of Lidas, Inc., a Delaware corporation…[more]