UNITED STATES v. SAMUELS, KRAMER AND CO.

No. 82-4537.

712 F.2d 1342 (1983)

UNITED STATES of America and Robert Merlo, Revenue Agent, Petitioners-Appellees, v. SAMUELS, KRAMER AND COMPANY; First Western Government Securities, Inc.; and the individuals, partnerships, joint ventures, associations, or corporations, for whom Samuels, Kramer and Company and First Western Government Securities, Inc., acting as principal, agent and/or broker purchased and/or sold any financial instruments or securities including those of or guaranteed by the United States or United States Government corporations or agencies, et al., Respondents-Appellants.

United States Court of Appeals, Ninth Circuit.

Decided August 12, 1983.


Attorney(s) appearing for the Case

William A. Whitledge, Dept. of Justice, Washington, D.C., for petitioners-appellees.

Richard J. Sideman, Sideman & Bancroft, San Francisco, Cal., for respondents-appellants.

Before HUG and FARRIS, Circuit Judges, and IRVING, District Judge.


HUG, Circuit Judge:

Samuels, Kramer and Co. and First Western Government Securities, Inc., challenge an order compelling them to comply with four IRS summonses, two of which are "John Doe" summonses. They primarily contend that the district court, in ordering the enforcement of the summonses, abused its discretion by denying their motions for (1) a de novo review of factual determinations underlying another district judge's authorization of the two John Doe summonses...

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