UNITED STATES v. CHASE MANHATTAN BANK

No. M-18-304 (CBM).

486 F.Supp. 317 (1979)

UNITED STATES of America, and William Sweerus, Special Agent, Internal Revenue Service, Petitioners, v. CHASE MANHATTAN BANK, Respondent, and Joel M. White, Intervenor.

United States District Court, S. D. New York.

October 9, 1979.


Attorney(s) appearing for the Case

Robert B. Fiske, Jr., U. S. Atty., S. D. N. Y., New York City (William J. Hibsher, Asst. U. S. Atty., New York City, of counsel), for petitioners.

John M. Bray, Schwalb, Donnenfeld, Bray & Silbert, Washington, D. C., Giora Ben-Horin, Brown & Bain, Phoenix, Ariz., Julian W. Friedman, Stillman & Friedman, New York City, for intervenor.


MEMORANDUM OPINION

MOTLEY, District Judge.

On November 6, 1978, this court heard oral argument by counsel for the government and the taxpayer concerning the Government's petition for enforcement of an administrative summons served on the Chase Manhattan Bank in connection with an IRS investigation of the taxpayer. The taxpayer, Joel M. White, had intervened pursuant to 26 U.S.C. § 7609(b)(1) on the grounds that the summons was not issued by the IRS...

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