UNITED STATES v. DEAK-PERERA INTERNATIONAL BANKING CORPORATION

No. 79-6035.

610 F.2d 89 (1979)

UNITED STATES of America and Barbara A. Kilty, Richard Gutierrez, Special Agents, Internal Revenue Service, Petitioners-Appellees, v. DEAK-PERERA INTERNATIONAL BANKING CORPORATION, Respondent, and Charles V. Stephenson, Intervenor-Appellant.

United States Court of Appeals, Second Circuit.

October 26, 1979.


Attorney(s) appearing for the Case

Richard Blumenthal, U. S. Atty., New Haven, Conn., George J. Kelly, Jr., Asst. U. S. Atty., Hartford, Conn., Dept. of Justice, Tax Division, M. Carr Ferguson, Gilbert E. Andrews, Washington, D. C., for appellee.

Charles V. Stephenson, pro se.

Before MULLIGAN, OAKES and NEWMAN, Circuit Judges.


The district court enforced two Internal Revenue summonses issued pursuant to I.R.C. § 7602, directing Deak-Perera, a financial institution, to forward documents in its possession relating to appellant Stephenson's financial status during the years 1975-1977. The documents were necessary to determine Stephenson's income tax liability in furtherance of an I.R.A. joint civil-criminal investigation. The day after the district court's order, Deak-Perera complied fully with...

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