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UNITED STATES v. MANUFACTURERS AND TRADERS TRUST CO.

No. 684, Docket 82-6220.

703 F.2d 47 (1983)

UNITED STATES of America and John C. Coppola, Special Agent Internal Revenue Service, Plaintiffs-Appellants, v. MANUFACTURERS AND TRADERS TRUST COMPANY, Defendant, Robert Jane and Wilhemina Jane, Intervenors-Appellees.

United States Court of Appeals, Second Circuit.

Decided March 18, 1983.

Attorney(s) appearing for the Case

William A. Whitledge, Atty., Tax Division, Dept. of Justice, Washington, D.C. (Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, and Charles E. Brookhart, Attys., Tax Division, Washington, D.C., and Salvatore R. Martoche, U.S. Atty., W.D.N.Y., Buffalo, N.Y., of counsel), for plaintiffs-appellants.

Joseph M. LaTona, Buffalo, N.Y. (Condon, LaTona & Klingensmith, P.C., Buffalo, N.Y., of counsel), for intervenors-appellees.

Before FEINBERG, Chief Judge, and CARDAMONE and DAVIS, Circuit Judges.

OSCAR H. DAVIS, Circuit Judge:

The refusal of the Western District of New York (Elfvin, J.) to enforce summonses issued by the Internal Revenue Service (IRS) at the request of and in aid of Canada raises questions under the United States-Canada Tax Convention of 1942. The prime problem is whether the IRS can obtain information needed by Canada to help determine a Canadian taxpayer's liability to it but also intended to be used by criminal investigators and prosecutors...

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