Legal Opinion

Agricultural Asset Management Co. v. United States

Court of Appeals for the Second Circuit

Decided August 31, 1982No. 1468, Docket 82-6112PublishedCited by 15 opinions

1Opinion of the Court

MALETZ, Judge:

Appellant Agricultural Asset Management Co., Inc. (Ag Asset) appeals from a memorandum decision and order of the District Court for the Northern District of New York (Roger J. Miner, Judge), enforcing an Internal Revenue Service John Doe summons.1 It contends that the District Court erred in ruling that Ag Asset, as the summoned party, may not challenge enforcement on the grounds that the Government has failed to comply with the criteria set forth in 26 U.S.C. § 7609(f).2

We hold that the District Court, in a well-reasoned opinion, correctly ruled that the criteria in 26 U.S.C. §…

2Cases cited12 opinions

  1. United States v. PowellSupreme Court of the United States · 1964
  2. Donaldson v. United StatesSupreme Court of the United States · 1971
  3. Reisman v. CaplinSupreme Court of the United States · 1964
  4. United States v. BiscegliaSupreme Court of the United States · 1975
  5. United States v. Morgan Guaranty Trust Company, and Roger L. Keech and Sandra J. Keech, Intervenors-AppellantsCourt of Appeals for the Second Circuit · 1978

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3Cited by15 opinions

  1. United States v. Robert W. Ritchie, Personally and in His Capacity as a Partner/officer of Ritchie, Fels & Dillard, P.C.Court of Appeals for the Sixth Circuit · 1994
  2. United States v. Tiffany Fine Arts, Inc.Court of Appeals for the Second Circuit · 1983
  3. United States v. Samuels, Kramer & Co.Court of Appeals for the Ninth Circuit · 1983
  4. United States v. Samuels, Kramer And CompanyCourt of Appeals for the First Circuit · 1983
  5. Robert L. Schulz v. Internal Revenue Service and Anthony Roundtree, Docket No. 04-0196-CvCourt of Appeals for the Second Circuit · 2005

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