UNITED STATES v. BISCEGLIA

No. 73-1245.

420 U.S. 141 (1975)

UNITED STATES ET AL. v. BISCEGLIA.

Supreme Court of United States.

Decided February 19, 1975.


Attorney(s) appearing for the Case

Stuart A. Smith argued the cause for the United States. With him on the brief were Solicitor General Bork, Assistant Attorney General Crampton, and Deputy Solicitor General Wallace.

William A. Watson argued the cause and filed a brief for respondent.*


MR. CHIEF JUSTICE BURGER delivered the opinion of the Court.

We granted certiorari to resolve the question whether the Internal Revenue Service has statutory authority to issue a "John Doe" summons to a bank or other depository to discover the identity of a person who has had bank transactions suggesting the possibility of liability for unpaid taxes.

I

On November 6 and 16, 1970, the Commercial Bank of Middlesboro, Ky., made two separate deposits...

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