United States of America and Earl Tripplett, Revenue Officer, Irs v. The First National Bank of Chicago

FAIRCHILD, Senior Circuit Judge.

The district court granted enforcement of an Internal Revenue Service summons directed to First National Bank of Chicago (First Chicago), seeking disclosure of certain records in First Chicago’s branch bank in Athens, Greece. We decide that First Chicago has adequately demonstrated that compliance will subject its employees to the risk of substantial criminal penalties under Greek law, and that balancing of relevant competing interests weighs against compelling disclosure at this time. We therefore reverse the judgment of the district court, but remand for…