UNITED STATES v. FRIEDMAN

Nos. 75-1276, 75-1277 and 75-1480.

532 F.2d 928 (1976)

UNITED STATES of America and William L. Beerman, Special Agent, Internal Revenue Service v. Paul FRIEDMAN et al., Appeal of Morris KIRSHENBAUM and Joy Kirshenbaum, Intervenors in District Court. UNITED STATES of America and William L. Beerman, Special Agent, Internal Revenue Service v. PITTSBURGH NATIONAL BANK et al., and Morris Kirshenbaum and Joy Kirshenbaum, Intervenors in D. C. UNITED STATES of America and William L. Beerman, Special Agent, Internal Revenue Service v. IVY SCHOOL OF PROFESSIONAL ART, INC. and Morris B. Kirshenbaum, as President of Ivy School of Professional Art, Inc. Appeal of Morris KIRSHENBAUM and Joy Kirshenbaum, Intervenors in D. C., and Ivy School of Professional Art, Inc., and Morris B. Kirshenbaum, as President of Ivy School of Professional Art, Inc. UNITED STATES of America and William L. Beerman, Special Agent, Internal Revenue Service, Appellants, v. PITTSBURGH NATIONAL BANK et al., Morris Kirshenbaum and Joy Kirshenbaum, Intervenors in D. C.

United States Court of Appeals, Third Circuit.

Decided March 22, 1976.


Attorney(s) appearing for the Case

Scott P. Crampton, Asst. Atty. Gen., Gilbert E. Andrews, Robert E. Lindsay, Jeffrey S. Blum, Attys., Tax Div., Dept. of Justice, Washington, D. C., for U. S. and William L. Beerman, Special Agent, I. R. S.; Blair A. Griffith, U. S. Atty., of counsel.

Robert A. Cohen, Emil W. Herman, Rothman, Gordon, Foreman & Groudine, Pittsburgh, Pa., for appellants-intervenors Morris Kirshenbaum and Joy Kirshenbaum.

B. A. Karlowitz, Donald L. Very, Tucker Arensberg & Ferguson, Pittsburgh, Pa., for Pittsburgh Nat. Bank.

Kenneth P. Simon, Reed Smith Shaw & McClay, Pittsburgh, Pa., for Mellon Bank, N. A.

Robert H. Stevenson, Anderson, Moreland & Bush, Pittsburgh, Pa., for Equibank N. A.

John Fletcher Rolph, III, Tax Counsel, Henry C. Ruempler, III, Asst. Tax Counsel, American Bankers Ass'n, Washington, D. C., for amicus curiae.


GIBBONS, Circuit Judge.

These appeals grow out of three separate proceedings in the district court for the enforcement, pursuant to 26 U.S.C. § 7604(b), of Internal Revenue Service (hereinafter IRS) summonses issued by Special Agent William L. Beerman in connection with an examination into the tax liabilities of Morris and Joy Kirshenbaum (hereinafter taxpayers) and the Ivy School of Professional Art, Inc. for the years 1969 through 1972. In one enforcement proceeding...

Let's get started

Leagle.com

Welcome to the leading source of independent legal reporting
Sign on now to see your case.
Or view more than 10 million decisions and orders.

  • Updated daily.
  • Uncompromising quality.
  • Complete, Accurate, Current.

Listed below are the cases that are cited in this Featured Case. Click the citation to see the full text of the cited case. Citations are also linked in the body of the Featured Case.

Cited Cases

  • No Cases Found

Listed below are those cases in which this Featured Case is cited. Click on the case name to see the full text of the citing case.

Citing Cases