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UNITED STATES v. SPEZZANO

Nos. MISC. CIV-82-119T to MISC. CIV-82-121T.

559 F.Supp. 631 (1982)

UNITED STATES of America and Anthony Trezza, Special Agent, Internal Revenue Service, Petitioners, v. Gerald W. SPEZZANO, Respondent. UNITED STATES of America and Anthony Trezza, Special Agent, Internal Revenue Service, Petitioners, v. William J. NEILD, Respondent. UNITED STATES of America and Anthony Trezza, Special Agent, Internal Revenue Service, Petitioners, v. Frank V. AVERY, Respondent.

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

August 12, 1982.

Attorney(s) appearing for the Case

David Rothenberg, Asst. U.S. Atty., Rochester, N.Y., for petitioners.

William J. Neild, Petralia, Neild & Webb, Rochester, N.Y., for respondent.

TELESCA, District Judge.

In this proceeding brought pursuant to 26 U.S.C. 7402(b) and 7604(a), the Internal Revenue Service (IRS) seeks judicial enforcement of three summonses requiring the production of certain records which are currently in the possession of the respondents. The three summonses were served upon the taxpayer, Frank Avery; the taxpayer's accountant, Gerald Spezzano; and the taxpayer's attorney, William Neild, Esq. All three summonses seek the production...

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