No. 113, Docket 78-6092.

587 F.2d 123 (1978)

UNITED STATES of America, and Felix Karul, Revenue Agent of the Internal Revenue Service, Petitioners-Appellees, v. Roger NOALL, as Executive Vice-President of Bunge Corporation, Respondent-Appellant.

United States Court of Appeals, Second Circuit.

Decided November 17, 1978.

Attorney(s) appearing for the Case

David M. Jones, Asst. U. S. Atty., S. D. N. Y. (Robert B. Fiske, Jr., U. S. Atty., S. D. N. Y., Louis G. Corsi and Frederick P. Schaffer, Asst. U. S. Attys., New York City, of counsel), for petitioners-appellees.

Bruce E. Pindyck, New York City (Olwine, Connelly, Chase, O'Donnell & Weyher, Edward A. Vrooman, Matthew M. McKenna and Gary Hoppe, New York City, of counsel), for respondent-appellant.

Before FRIENDLY, MULLIGAN and GURFEIN, Circuit Judges.

FRIENDLY, Circuit Judge:

The United States and Felix Karul, an IRS agent, brought this proceeding in the District Court for the Southern District of New York under IRC §§ 7402(b) and 7604(a) to enforce an IRS summons directed to Roger Noall, Executive Vice-President of the taxpayer, Bunge Corporation (Bunge). The petition recited that Karul was conducting an investigation for the purpose of ascertaining the correctness of Bunge's income tax returns for the...

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