United States v. Williams

MOTLEY, District Judge.

Memorandum Opinion

The government petitions pursuant to 26 U.S.C. §§ 7402(b) and 7604(a) to enforce an Internal Revenue Service summons issued for the purpose of determining the tax liability of intervenor Rudolph Wittenberg for the years 1966, 1967 and 1968. In 1969, as a result of an independent investigation, the IRS claims to have discovered that certain checks paid to Wittenberg, a practicing psychologist, were not reported on his returns for the years 1966-68. As a result, the taxpayer reviewed his records and filed amended returns for those years showing higher…