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UNITED STATES v. MANUFACTURERS BANK OF SOUTHFIELD

Civ. A. Nos. 81-70159 to 81-70163.

518 F.Supp. 495 (1981)

UNITED STATES of America, and Ken Szymanski, Revenue Agent, Internal Revenue Service, Petitioners, v. MANUFACTURERS BANK OF SOUTHFIELD, Respondent. UNITED STATES of America, and Ken Szymanski, Revenue Agent, Internal Revenue Service, Petitioners, v. MICHIGAN NATIONAL BANK OF OAKLAND, Respondent. UNITED STATES of America, and Ken Szymanski, Revenue Agent, Internal Revenue Service, Petitioners, v. CAPITOL SAVINGS & LOAN, Respondent. UNITED STATES of America, and Ken Szymanski, Revenue Agent, Internal Revenue Service, Petitioners, v. MICHIGAN NATIONAL BANK OF OAKLAND, Respondent. UNITED STATES of America, and Ken Szymanski, Revenue Agent, Internal Revenue Service, Petitioners, v. COVENANT CREDIT UNION, Respondent.

United States District Court, E. D. Michigan, S. D.

April 8, 1981.

Attorney(s) appearing for the Case

D. Patrick Mullarkey, Tax Div., U.S. Dept. of Justice, Washington, D.C., Richard A. Rossman, U.S. Atty., Detroit, Mich., for the U.S.

Raymond L. Morrow, Southfield, Mich., for respondents.

MEMORANDUM OPINION AND ORDER

PHILIP PRATT, District Judge.

The Internal Revenue Service (IRS) directed summonses to the respondent banks in these five cases, seeking records relating to the finances of Marvin I. Niskar and Joanne Niskar (the taxpayers) for the years 1977 through 1979.1 The taxpayers administratively stayed compliance with the summonses. Then the IRS instituted these cases by filing petitions to enforce the summonses...

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