United States of America v. Shell et al

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IN THE UNITED STATES DISTRICT COURT FOR THE
WESTERN DISTRICT OF MISSOURI
CENTRAL DIVISION
UNITED STATES OF AMERICA,
Plaintiff,
v.
CHARLES SHELL, et al.,
Defendants.
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Case No. 2:25-MC-09001-BCW
ORDER
Before the Court is Chief Magistrate Judge Willie J. Epps, Jr.’s Report and
Recommendation (Doc. #10) concerning the United States’ Petition to Enforce Internal Revenue
Service Summonses (Doc. #1).
On July 2, 2025, the United States filed a Petition to Enforce Internal Revenue Service
(“IRS”) Summonses against Defendants Charles Shell and Shell Engineering & Associates, Inc.
(“Shell Engineering”). (Doc. #1). Defendants were served on July 9, 2025. (Doc. #3). On
September 4, 2025, Judge Epps entered a show cause order directing Defendants to show cause
why the summonses should not be enforced within 20 days. (Doc. #4). As of the date of this Order,
neither Defendant has filed an answer or entered an appearance in this matter.
On October 21, 2025, Judge Epps issued a Report and Recommendation recommending
dismissal of the Petition for failure to prosecute. (Doc. #5). The United States filed objections that,
after consideration, led Judge Epps to withdraw his initial Report and Recommendation. (Doc. #9).
On December 4, 2025, Judge Epps issued the instant Report and Recommendation
recommending the claim against Mr. Shell be dismissed and the Petition be enforced against Shell
Engineering. (Doc. #10). The deadline to file objections has passed and Defendant has not filed
any objections.
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The Court, after an independent review of the record and the applicable law, adopts the
Magistrate’s Report and Recommendation. Accordingly, it is hereby
ORDERED that the Magistrate’s Report and Recommendation (Doc. #10) be attached to
and made part of this Order. It is further
ORDERED Defendant Charles Shell is DISMISSED from this case for the reasons stated
in the Report and Recommendation. It is further
ORDERED the United States’ Petition to Enforce Internal Revenue Service Summonses
(Doc. #1) is GRANTED for the reasons stated in the Report and Recommendation. It is further
ORDERED Shell Engineering & Associates, Inc. shall obey the Internal Revenue Service
summons issued to it on January 24, 2025, and each requirement of the summons at such time and
place as may hereafter be designated by Revenue Officer Brent J. Garcia or any other proper officer
or employee of the Internal Revenue Service, but not later than 30 days of the date Shell
Engineering & Associates, Inc. receives service of this Order.
IT IS SO ORDERED.
Dated: January 14, 2026 /s/ Brian C. Wimes
BRIAN C. WIMES, CHIEF JUDGE
UNITED STATES DISTRICT COURT
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