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UNITED STATES v. SUN FIRST NATIONAL BANK OF ORLANDO

No. 74-1453.

510 F.2d 1107 (1975)

UNITED STATES of America and Edward P. Cory, Revenue Agent, Internal Revenue Service, Petitioners-Appellees, v. SUN FIRST NATIONAL BANK OF ORLANDO and Clifford M. Hames, Respondents-Appellants.

United States Court of Appeals, Fifth Circuit.

Rehearing and Rehearing Denied May 16, 1975.

Attorney(s) appearing for the Case

J. Thomas Cardwell, Orlando, Fla., for respondents-appellants.

John L. Briggs, U. S. Atty., Harrison T. Slaughter, Jr., Asst. U. S. Atty., Orlando, Fla., Scott P. Crampton, Asst. Atty. Gen., Meyer Rothwacks, Chief, Appellate Sec., Dennis M. Donohue, John P. Burke, William A. Whitledge, Attys., Tax Div., Dept. of Justice, Washington, D. C., for petitioners-appellees.

Before BELL, AINSWORTH and RONEY, Circuit Judges.

Rehearing and Rehearing En Banc Denied May 16, 1975.

RONEY, Circuit Judge:

Sun First National Bank of Orlando and Clifford M. Hames, its Vice-President and Trust Officer, appeal from the district court's enforcement of a Section 7602 administrative summons of the Internal Revenue Service issued by Revenue Agent Edward P. Cory. We affirm.

The summons was issued in the matter of the tax liability of thirty-two named trusts handled by the bank's trust...

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