MATTER OF DOES

No. 80-3584.

671 F.2d 977 (1982)

In the Matter of The Tax Liabilities of John DOES, Members of the Columbus Trade Exchange in the Years 1977 and 1978 United States of America, Petitioner-Appellant.

United States Court of Appeals, Sixth Circuit.

Decided March 3, 1982.


Attorney(s) appearing for the Case

James C. Cissell, U. S. Atty., Richard D. Letts, Asst. U. S. Atty., Columbus, Ohio, John F. Murray, William A. Whitledge, Steven Toscher, M. Carr Ferguson, Trial Atty., Tax Div., U. S. Dept. of Justice, Washington, D. C., for the U. S.

David J. Curtin, Washington, D. C., for Members of the Columbus Trade Exchange.

Before EDWARDS, Chief Judge, MARTIN, Circuit Judge, and REED, District Judge.


PER CURIAM.

This case requires us to consider the circumstances under which the Internal Revenue Service may seek to ascertain the identities of unknown taxpayers through the issuance of "John Doe" summonses. A "John Doe" summons is, in essence, a direction to a third party to surrender information concerning taxpayers whose identity is currently unknown to the IRS.

Until 1976, there was no statutory restraint on the Commissioner's use of this device. However...

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