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UNITED STATES v. RICHTER

No. 79-1064.

603 F.2d 744 (1979)

UNITED STATES of America, and William D. Runge, Special Agent of Internal Revenue Service, Appellees, v. Ms. Cynthia RICHTER, Manager, Missouri Savings Association, and Missouri Savings Association, Mrs. Connie Moody, Supervisor of the Loan and Discount Department, Southern Commercial Bank, and Southern Commercial Bank, Mr. Jerry Stern, Vice-President, President, Treasurer, Landmark Bank, James T. Helm, Cashier, United Missouri Bank of Jefferson County, and United Missouri Bank of Jefferson County, Dale T. and Georgia S. Jackson, Intervenors-Appellants.

United States Court of Appeals, Eighth Circuit.

Decided August 21, 1979.

Attorney(s) appearing for the Case

Samuel T. Vandover, of Godfrey, Vandover & Burns, Inc., St. Louis, Mo., on brief, for intervenors-appellants.

Robert D. Kingsland, U. S. Atty., and Bruce D. White, Asst. U. S. Atty., St. Louis, Mo., on brief, for appellees.

Before GIBSON, Chief Judge, VOGEL, Senior Circuit Judge, and BRIGHT, Circuit Judge.

PER CURIAM.

This case is a consolidation of four appeals, taken by taxpayers Dale T. and Georgia S. Jackson (intervenors below), from the district court's1 enforcement of four third-party summonses issued by the Internal Revenue Service (IRS). Appellants contend the district court erred in limiting their attempt to prove that IRS's sole purpose for issuing the summonses was to prepare a criminal prosecution of appellants and that the summonses...

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