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UNITED STATES v. FIRST STATE BANK

No. 81-1495.

691 F.2d 332 (1982)

UNITED STATES of America and Robert C. Rowe, Special Agent, Internal Revenue Service, Petitioners-Appellees, v. FIRST STATE BANK and Christ Troupis, Respondents, and E. H. Stamberger, Intervenor-Appellant.

United States Court of Appeals, Seventh Circuit.

Decided October 12, 1982.

Rehearing and Rehearing Denied November 10, 1982.

Attorney(s) appearing for the Case

Clinton A. Krislov, Chicago, Ill., for intervenor-appellant.

Gayle P. Miller, Tax Div., Dept. of Justice, Washington, D. C., for petitioners-appellees.

Before SWYGERT, Senior Circuit Judge, ESCHBACH, Circuit Judge, and DOYLE, Senior District Judge.

Rehearing and Rehearing En Banc Denied November 10, 1982.

SWYGERT, Senior Circuit Judge.

The facts pertinent to this appeal may be summarized as follows. In January 1978, the Internal Revenue Service ("IRS") commenced an investigation of E. H. Stamberger's tax liabilities for the years 1975 and 1976. The investigation involved agents of both the Examination Division (civil division) and the Criminal Investigation Division of the IRS. The investigation was...

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