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UNITED STATES v. FRIEDMAN

Civ. A. Nos. 74-195, 74-346, 74-557.

388 F.Supp. 963 (1975)

UNITED STATES of America and William L. Bierman, Special Agent Internal Revenue Service, Petitioners, v. Paul FRIEDMAN, Respondent, and Morris Kirshenbaum and Joy Kirshenbaum, Intervenors. UNITED STATES of America and William L. Bierman, Special Agent Internal Revenue Service, Petitioners, v. PITTSBURGH NATIONAL BANK et al., Respondents, and Morris Kirshenbaum and Joy Kirshenbaum, Intervenors. UNITED STATES of America and William L. Bierman, Special Agent Internal Revenue Service, Petitioners, v. IVY SCHOOL OF PROFESSIONAL ART, INC. and Morris B. Kirshenbaum, as president of Ivy School of Professional Art, Inc., Respondents.

United States District Court, W. D. Pennsylvania.

February 3, 1975.

Attorney(s) appearing for the Case

Thomas A. Daley, Asst. U. S. Atty., Pittsburgh, Pa., Stephen G. Fuertl Tax Div. Dept. of Justice, Wash. D. C., for petitioners.

Stanley W. Greenfield, Pittsburgh, Pa., for Paul Friedman.

James B. Brown, Rothman, Gordon, Foreman & Groudine, Pittsburgh, Pa., for Morris and Joy Kirshenbaum, and Ivy School of Professional Art, Inc.

B. A. Karlowitz, Pittsburgh, Pa., for Pittsburgh Nat. Bank.

Kenneth P. Simon, Pittsburgh, Pa., for Mellon Bank.

Robert H. Stevenson, Pittsburgh, Pa., for Equibank.

TEITELBAUM, District Judge.

OPINION

On December 11, 1973, three Internal Revenue Service (IRS) summonses [Treasury Form 2039] were issued by Special Agent William L. Bierman of the IRS and served upon defendants Pittsburgh National Bank (PNB), Mellon Bank, N. A. (Mellon) and EQUIBANK, under purported authority of 26 U.S.C. § 7602. The summonses requested all records pertaining to Morris and Joy Kirshenbaum and the Ivy School of Professional Art, Inc...

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