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UNITED STATES v. UNIVERSITY SAV. ASS'N

No. 81-2019.

666 F.2d 312 (1982)

UNITED STATES of America and Internal Revenue Service Officer, David L. Ackley, Plaintiffs-Appellees Cross-Appellants, v. UNIVERSITY SAVINGS ASSOCIATION and Emily Clark, Collection Supervisor, Defendants, Paul V. Watson, et al., Intervenors-Appellants Cross-Appellees.

United States Court of Appeals, Fifth Circuit.

January 28, 1982.

Attorney(s) appearing for the Case

Jeffrey H. Hubbard, Houston, Tex., for Paul V. Watson, et al.

Jim Ezer, Asst. U. S. Atty., Houston, Tex., John F. Murray, Acting Asst. Atty. Gen., Michael L. Paup, Chief, Appellate Section, Charles E. Brookhart, William A. Whitledge, Attys., Dept. of Justice, Washington, D. C., for intervenors-appellants cross-appellees.

Before GEE, GARZA and SAM D. JOHNSON, Circuit Judges.

GEE, Circuit Judge:

The United States of America and Internal Revenue Service Agent David L. Ackley brought a consolidated action to enforce seven Internal Revenue Service summonses against six financial institutions and one accounting firm to obtain records pertaining to Paul V. and Sharon E. Watson ("Watsons") in connection with an investigation of the tax liability of Paul V. Watson for the years 1976 through 1978. The trial court denied enforcement of the summonses...

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