Court of Appeals for the Sixth Circuit January 21, 1997, 95-2055 (Thomas M. Cook and Carol L. Cook v. United States)

KRUPANSKY, Circuit Judge.

The plaintiffs-appellants, Thomas M. Cook (“Cook”) and Carol L. Cook, a married couple (“the Cooks”) have contested the district court’s dismissal, for failure to state a claim, of their petition to quash an administrative summons issued by the Internal Revenue Service (“I.R.S.” or the Service ).