UNITED STATES v. HADDAD

No. 75-1351.

527 F.2d 537 (1975)

UNITED STATES of America, and Joseph H. Romine, Special Agent of the Internal Revenue Service, Petitioners-Appellees, v. Frank E. HADDAD, Jr., Respondent-Appellant.

United States Court of Appeals, Sixth Circuit.

Decided December 10, 1975.


Attorney(s) appearing for the Case

Frank A. Logan, Louisville, Ky., for respondent-appellant.

Melvin B. Lewis, Chicago, Ill., for amicus curiae.

George J. Long, U. S. Atty., Louisville, Ky., Scott P. Crampton, Asst. Atty. Gen., Gilbert E. Andrews, Tax Div., Dept. of Justice, Washington, D. C., Robert E. Lindsay, Charles E. Brookhart, Washington, D. C., for petitioners-appellees.

Before WEICK, MILLER and ENGEL, Circuit Judges.


William E. MILLER, Circuit Judge.

This is an appeal from an order of the district court, Western District of Kentucky, enforcing a summons issued pursuant to 26 U.S.C. Sec. 7601 et seq. by an agent of the Internal Revenue Service ("IRS").

The appellant ("Haddad"), an attorney, had represented one Ray Palmer and others in a criminal case in 1971. After the conclusion of the criminal case, IRS issued a tax assessment for excise taxes allegedly due from...

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