This appeal tests the enforceability of an administrative summons issued under § 7602 of the Internal Revenue Code of 1954, 26 U.S.C. § 7602, and served upon the Continental Bank and Trust Company ("the bank") pursuant to § 7603 of the Code, 26 U.S.C. § 7603.
The summons was issued by special agent Thomas L. Harkness of the Internal Revenue Service in connection with his investigation...
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