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UNITED STATES v. TIFFANY FINE ARTS, INC.

No. 1006, Docket 82-6336.

718 F.2d 7 (1983)

UNITED STATES and Joel Lewis, Revenue Agent, Internal Revenue Service, Petitioners-Appellees, v. TIFFANY FINE ARTS, INC. and its subsidiaries, including World Medical Marketing Corporation and World Video Corp., Respondents-Appellants.

United States Court of Appeals, Second Circuit.

Decided September 13, 1983.

Attorney(s) appearing for the Case

David M. Rubin, New York City (Michael D. Savage, Gersten, Savage & Kaplowitz, New York City, of counsel), for respondents-appellants.

Jamie Vincent Gregg, New York City, Asst. U.S. Atty., S.D.N.Y. (John S. Martin, Jr., U.S. Atty., S.D.N.Y., David M. Jones, Asst. U.S. Atty., Thomas D. Warren, Asst. U.S. Atty., of counsel), for petitioners-appellees.

Before KEARSE, PIERCE and PRATT, Circuit Judges.

GEORGE C. PRATT, Circuit Judge:

Tiffany Fine Arts, Inc. and two subsidiaries, World Medical Marketing Corp. and World Video Corp., (collectively referred to as Tiffany) appeal from an order of the District Court for the Southern District of New York (Vincent L. Broderick, Judge), enforcing four Internal Revenue Service administrative summonses. Tiffany's principal contention on appeal is that before issuing the summonses the IRS was required to comply with...

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