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UNITED STATES v. NORTHWESTERN NAT. BANK

No. 80-1559.

634 F.2d 394 (1980)

UNITED STATES of America and Bradley P. Whites, Special Agent of the Internal Revenue Service, Appellees, v. NORTHWESTERN NATIONAL BANK, through Wallace B. Hanson, Vice-President; and First Baltic Branch, First National Bank of Sioux Falls, through Lynn Aspaas, Vice-President, Respondents, v. Robert A. LARSEN, Intervenor-Appellant.

United States Court of Appeals, Eighth Circuit.

Decided November 14, 1980.

Attorney(s) appearing for the Case

Robert A. Larsen, appellant-without counsel.

M. Carr Ferguson, Asst. Atty. Gen., Michael L. Paup, Daniel F. Ross, Philip I. Brennan, Attys., Tax Division, Dept. of Justice, Washington, D.C., filed brief, for appellees; Terry L. Pechota, U.S. Atty., of counsel.

Before BRIGHT, ROSS and McMILLIAN, Circuit Judges.

PER CURIAM.

Appellant, Robert A. Larsen (Taxpayer), appeals from an order of the district court1 enforcing two IRS summonses for the purpose of determining his income tax liability for 1977-78. Taxpayer in his pro se appeal asserts three principal challenges to the enforcement of the summonses: (1) the constitutionality of the IRS to issue the summonses and of the district court to enforce...

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