Union Bank of Switzerland v. HS Equities, Inc.

OPINION

EE)WARD WEINFELD, District Judge.

Plaintiff, a Swiss banking corporation, alleges in its complaint that in 1967 it opened a brokerage account with defendant on behalf of one of plaintiff’s clients, named Zelmanowitz. Thereafter plaintiff, acting as Zelmanowitz’s agent, engaged in various securities transactions through defendant. The proceeds of these transactions remained in plaintiff’s account with defendant; correspondingly, plaintiff credited Zelmanowitz’s account with it, in Geneva, with the appropriate amounts. In 1967 the United States initiated an attempt to recover taxes owed…