UNITED STATES v. CORTESE

No. 78-2005.

614 F.2d 914 (1980)

UNITED STATES of America and Joseph A. Dollard, Special Agent, Internal Revenue Service, Plaintiffs-Appellants, v. Americo V. CORTESE, Prothonotary, Court of Common Pleas, Philadelphia County, PB, JB, JJD, LK, SK, MK, SLL, ML-1, ML-2, Intervenors-Defendants. Appeal of UNITED STATES of America.

United States Court of Appeals, Third Circuit.

Decided February 8, 1980.


Attorney(s) appearing for the Case

Daniel F. Ross (argued), M. Carr Ferguson, Gilbert E. Andrews, Joseph M. Gontram, Robert E. Lindsay, Washington, D. C., Peter F. Vaira, Jr., U.S. Atty., Philadelphia, Pa., for plaintiffs-appellants.

Robert C. Daniels (argued), Philip L. Blackman, Adler, Barish, Daniels, Levin, & Creskoff, Philadelphia, Pa., for intervenors-defendants.

Jonathan Vipond, III, Philadelphia, Pa., for Americo V. Cortese.

Before HUNTER, WEIS and GARTH, Circuit Judges.


OPINION OF THE COURT

JAMES HUNTER, III, Circuit Judge.

This case requires us once again to examine the requirement that Internal Revenue Service (IRS) summonses be issued in good faith pursuit of the congressionally authorized purposes of 26 U.S.C. § 7602.1 United States v. LaSalle National Bank, 437 U.S. 298, 318, 98 S.Ct. 2357, 2368, 57 L...

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