Claire Kelley v. United States of America

Appellant, a depositor of the Bank of America, seeks to enjoin the enforcement of an Internal Revenue Service summons issued pursuant to 26 U.S.C. § 7602. The summons commanded the officers of the bank to produce for examination “[a] 11 bank statements, ledger sheets, canceled checks, or any other records pertaining to the above named taxpayer in your possession or control which reflect deposit or withdrawal transactions or any other transactions in the checking, savings, or loan accounts with the Bank of America.” Appellant asserts that production of the demanded records will violate her…