State, Department of Revenue v. Moore

OPINION

DROWOTA, Justice.

On direct appeal from the Chancery Court of Marion County, this case arises out of a petition to enforce an investigative summons issued by the Department of Revenue, the Petitioner. The summons was issued by Petitioner to the Respondent, First Bank of Marion County, in the course of an investigation of the potential tax liability of one of Respondent’s customers. Intervenor, Buck Layne, Jr., is the customer who is the subject of an ongoing Department of Revenue investigation. Several significant issues are presented by this case.

I. The Facts

The facts are simple and…