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U.S. DEPARTMENT OF JUSTICE

Tax Division

P.O. Box 683, Ben Franklin Station

ORDER TO SHOW CAUSE Washington, D.C. 20044-0683

(Civ. No. MS06-5017) - 1 - Telephone: (202) 514-95931812832.1 

UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF WASHINGTON 

AT TACOMA

UNITED STATES OF AMERICA, )

)

Petitioner, )

)

 v. )

)

EFFIE LIGON, individually, and as managing )

partner of IBIS GROUP, LLC, and as trustee )

of IBIS COMPANY TRUST, )

 )

)

Respondent. ) 

Case No. MS06-5017 FDB/KLS

ORDER TO SHOW CAUSE RE: 

PETITION TO ENFORCE

INTERNAL REVENUE SERVICE

SUMMONSES

Upon the petition of the United States and the Declaration of Revenue Agent Paul R. Shipley,

including the exhibits attached thereto, it is hereby

ORDERED that respondent Effie Ligon appear before United States Magistrate Judge Karen L.

Strombom in Courtroom F, of the United States District Court located at 1717 Pacific Avenue, Tacoma,

Washington, on the 25th day of August, 2006, at 9:00 a.m., to show cause why she should not be

compelled to obey the Internal Revenue Service summonses served upon her.

Case 3:06-mc-05017-FDB Document 4 Filed 07/31/06 Page 1 of 4
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U.S. DEPARTMENT OF JUSTICE

Tax Division

P.O. Box 683, Ben Franklin Station

ORDER TO SHOW CAUSE Washington, D.C. 20044-0683

(Civ. No. MS06-5017) - 2 - Telephone: (202) 514-95931812832.1 

///

///

It is further ORDERED that:

1. A copy of this Order, together with the petition and declaration with attached exhibits, shall

be served upon respondent in accordance with Fed. R. Civ. P. 4, within 21 days of the date that this Order

is served upon counsel for the United States or as soon thereafter as possible. Pursuant to Fed. R. Civ. P.

4, the Court hereby appoints Revenue Paul R. Shipley, or his designee, to serve process in this case.

2. Proof of any service done pursuant to paragraph 1, above, shall be filed with the Clerk of

Court as soon as practicable.

3. Since the file in this case reflects a prima facie showing that the examination is being

conducted for a legitimate purpose, that the inquiry may be relevant to that purpose, that the information

sought is not already within the Commissioner's possession, and that the administrative steps required by

the Internal Revenue Code have been followed, United States v. Powell, 379 U.S. 48, 57-58 (1964), the

burden of coming forward has shifted to respondent to oppose enforcement of the summonses.

4. If respondent has any defense to present or opposition to the petition, such defense or

opposition shall be made in writing and filed with the Clerk of Court and copies served on counsel for the

United States in Washington D.C., at least 14 days prior to the date set for the show cause hearing. The

United States may file and serve a reply memorandum to any opposition at least 5 court days prior to the

date set for the show cause hearing.

5. At the show cause hearing, the Court will consider all issues raised by respondent. Only

those issues brought into controversy by the responsive pleadings and supported by affidavit will be

considered. Any uncontested allegation in the petition will be considered admitted.

6. Respondent may notify the Court, in a writing filed with the Clerk and served on counsel for

the United States in Washington, D.C., at least 14 days prior to the date set for the show cause hearing,

that respondent has no objection to enforcement of the summons. The respondent's appearance at the

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U.S. DEPARTMENT OF JUSTICE

Tax Division

P.O. Box 683, Ben Franklin Station

ORDER TO SHOW CAUSE Washington, D.C. 20044-0683

(Civ. No. MS06-5017) - 3 - Telephone: (202) 514-95931812832.1 

show cause hearing will then be excused.

Respondent is hereby notified that failure to comply with this Order may subject respondent to

sanctions for contempt of court.

The Clerk shall forward copies of this Order to counsel for the United States, at the address

indicated on its pleadings.

DATED: July 31, 2006.

A

Karen L. Strombom

United States Magistrate Judge

Submitted by:

JOHN MCKAY

United States Attorney

ROBERT BROUILLARD

Assistant United States Attorney

s/ Jennifer D. Auchterlonie 

JENNIFER D. AUCHTERLONIE, WSBA 29481

Trial Attorney, Tax Division

U.S. Department of Justice

Post Office Box 683

Ben Franklin Station

Washington, D.C. 20044

Telephone: (202) 514-9593

Facsimile: (202) 307-0054

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U.S. DEPARTMENT OF JUSTICE

Tax Division

P.O. Box 683, Ben Franklin Station

ORDER TO SHOW CAUSE Washington, D.C. 20044-0683

(Civ. No. MS06-5017) - 4 - Telephone: (202) 514-95931812832.1 

E-mail: Jennifer.D.Auchterlonie@USDOJ.gov

Case 3:06-mc-05017-FDB Document 4 Filed 07/31/06 Page 4 of 4