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Administrative Enterprises, also admitted at the hearing that she
disposed of some documents after she received the IRS summons and
claimed that documents relating to Administration Co. were never
returned to her from bankruptcy counsel.42 On May 20, 1994, the
District Court ordered the records sought by the summonses be
produced to the IRS by May 24, 1994. United States v.
Administration Co., 74 AFTR 2d 94-5252, 94-2 USTC par. 50,480
(N.D. Ill. 1994).
Although Gallenberger appeared, testified, and produced
some documents on May 24, 1994, in accordance with the District
Court's order, she did not search all of the approximately 52
filing cabinets of records in her possession, but instead looked
in every fifth or seventh file. The Government filed another
motion on June 10, 1994, and, on June 22, 1994 a hearing was
held. See United States v. Administration Co., 74 AFTR 2d 94-
5256, 94-2 USTC par. 50,480 (N.D. Ill. 1994). At this second
hearing, Gallenberger admitted that Principal Services operated
42
During the bankruptcy proceeding for Administration Co., the
only documents that bankruptcy counsel for Administration Co. may
have received from Administration Co. were copies of its tax
returns. He received none of the books and records of the
clients of Administration Co. The documents sought by the
summons which was the subject of the summons enforcement
proceeding did not ask for the tax returns of Administration Co.
The summons sought the books and records relating to transactions
involving the Kanters for the years 1983, 1985, 1986, 1987 and
1988. These records were not given to the bankruptcy counsel.
They were given to Kanter.
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