UNITED STATES v. SAPP

No. FL 73-125-Civ-NCR.

371 F.Supp. 532 (1974)

UNITED STATES of America and Michael R. McDonald, Special Agent, Internal Revenue Service, Petitioners, v. Edwin SAPP, Respondent, and William F. Pelski and Eva Pelski, Intervenors.

United States District Court, S. D. Florida, Fort Lauderdale Division.

January 30, 1974.


Attorney(s) appearing for the Case

James H. Jeffries, Jon R. Eggleston, Tax Div., U. S. Dept. of Justice, Washington, D. C., Robert Rust, U. S. Atty., Robert N. Reynolds, Asst. U. S. Atty., Miami, Fla., for petitioners.

Louis J. DeReuil, Isley & DeReuil, Fort Lauderdale, Fla., for respondent.

Theodore Klein, Fine, Jacobson, Block & Semet, Miami, Fla., for intervenors.


FINDINGS OF FACT AND CONCLUSIONS OF LAW

ROETTGER, District Judge.

FINDINGS OF FACT

The United States of America sought to obtain a ledger of individual taxpayers for the calendar years 1971 and 1972 by a summons directed to the respondent, Edwin Sapp, a certified public accountant. The taxpayers, Mr. and Mrs. William F. Pelski, demanded of Mr. Sapp that he not turn over the ledger and claimed a privilege under the Fifth Amendment. The taxpayers...

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