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U.S. v. ADLMAN

No. 704, Docket 94-6143.

68 F.3d 1495 (1995)

UNITED STATES of America, Petitioner-Appellee, v. Monroe ADLMAN, as Officer and Representative of Sequa Corporation, Respondent-Appellant.

United States Court of Appeals, Second Circuit.

Decided October 26, 1995.

Attorney(s) appearing for the Case

William J. Hoffman, Assistant United States Attorney, New York City (Mary Jo White, United States Attorney for the Southern District of New York, Steven M. Haber, Assistant United States Attorney, of counsel), for Petitioner-Appellee.

John J. Tigue, Jr., New York City (Linda A. Lacewell, Morvillo, Abramowitz, et al., and Bryan C. Skarlatos, Kostelanetz & Fink, of counsel), for Respondent-Appellant.

Before: MAHONEY, LEVAL, and CALABRESI, Circuit Judges.

LEVAL, Circuit Judge:

This is an action brought by the United States to enforce an Internal Revenue Service summons issued to Monroe Adlman, as Officer and Representative of Sequa Corporation ("Sequa"). See 26 U.S.C. § 7604 (conferring power upon the district courts to enforce an IRS summons). The summons sought production of a preliminary and final draft of a memorandum prepared by Sequa's auditors, Arthur Andersen & Co. ("AA"), at Adlman's request...

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