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UNITED STATES v. EGENBERG

No. 18518.

443 F.2d 512 (1971)

UNITED STATES of America, Appellant, and Bernard O. Peller, Special Agent, Internal Revenue Service, v. Norman H. EGENBERG.

United States Court of Appeals, Third Circuit.

Decided May 26, 1971.

Attorney(s) appearing for the Case

John M. Brant, U. S. Dept. of Justice, Tax Division, Washington, D. C. (Johnnie M. Walters, Asst. Atty. Gen., Lee A. Jackson, Joseph M. Howard, Attys., Dept. of Justice, Washington, D. C., Fred B. Lacey, U. S. Atty., on the brief), for appellant.

Norman H. Egenberg, pro se.

Before GANEY, VAN DUSEN and GIBBONS, Circuit Judges.

OPINION OF THE COURT

GIBBONS, Circuit Judge.

The Government appeals from an order of the district court which denied judicial enforcement of twelve Internal Revenue Service summonses issued under authority of Section 7602 of the Internal Revenue Code of 1954, 26 U.S.C. § 7602 (1964), and Treasury Regulation § 301.7602-1 (T.D. 6421, October 23, 1959, and T.D. 6498, October 24, 1960). The petition to the district court was filed pursuant to Sections...

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