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WILD v. UNITED STATES

No. 20537.

362 F.2d 206 (1966)

Albert J. WILD and Air Conditioning Supply Co., Inc., Appellants, v. UNITED STATES of America, Bennett Y. Brewer, and Valley National Bank, Appellees.

United States Court of Appeals Ninth Circuit.

June 2, 1966.

Attorney(s) appearing for the Case

W. Lee McLane, Jack E. Brown, Arthur P. Allsworth, Brown, Vlassis & Bain, Phoenix, Ariz., for appellants.

Richard M. Roberts, Acting Asst. Atty. Gen., Lee A. Jackson, Joseph M. Howard, Burton Berkley, Attys., Dept. of Justice, Washington, D. C., Wm. P. Copple, U. S. Atty., Richard C. Gormley, Asst. U. S. Atty., Phoenix, Ariz., for appellees United States and Brewer.

Before MADDEN, Judge of the Court of Claims, and HAMLEY and MERRILL, Circuit Judges.

HAMLEY, Circuit Judge.

In 1965, Bennett Y. Brewer, a special agent of the Internal Revenue Service, was conducting an investigation of the tax affairs of Albert J. Wild and Air Conditioning Supply Company for the years 1960 to 1962.1 Pursuant to this investigation, and purporting to act on the authority of section 7602 of the Internal Revenue Code of 1954 (Code), 26 U.S.C. § 7602 (1964),...

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