United States v. Giordano

MEMORANDUM OPINION

HARPER, Chief Judge.

This is an action by the United States and its agent, to obtain judicial enforcement of a summons of the Internal Revenue Service. Jurisdiction is based upon the express provisions of 26 U.S. C.A. §§ 7604(a) and 7402(b).

The petitioner McGuire is a special agent of the Intelligence Division of the Internal Revenue Service and is at present conducting an investigation, together with Revenue Agent J. B. Marchbein, of the federal income tax liability of the Banana Distributing Company of *886St. Louis, Inc. This investigation was begun in relation to the tax…