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UNITED STATES v. RYAN

No. M-18-304 (IBC).

485 F.Supp. 1285 (1980)

UNITED STATES of America, Petitioner, v. Jack RYAN, as partner of Herzfeld & Stern, Respondent, and Melvin Shenweather, Intervenor.

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

February 29, 1980.

Attorney(s) appearing for the Case

Robert B. Fiske, Jr., U. S. Atty., S. D. N. Y., New York City, for petitioner; Stanley D. Davis, Asst. U. S. Atty., New York City, of counsel.

Philip T. Weinstein, Miami, Fla., for intervenor.

OPINION

IRVING BEN COOPER, District Judge.

In this summary judgment application, we are asked to determine the validity of summary enforcement (without discovery) of a third-party administrative summons issued by the Internal Revenue Service pursuant to a tax investigation.

The Facts

Internal Revenue Service (IRS) Special Agent Charles Brock, Criminal Investigation Division, is conducting an investigation into the income tax records of...

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