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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