Legal Opinion
Middleton v. United States
District Court, N.D. Ohio
Decided March 22, 1985No. C83-2419, C83-2439PublishedCited by 1 opinion
1Opinion of the Court
MEMORANDUM OPINION AND ORDER
BATTISTI, Chief Judge.
Petitioners David J. Middleton and June C. Middleton filed on June 9,1983 a petition to quash summonses issued by Respondent Internal Revenue Service. Petitioner Life Science Church, through David Middleton, its trustee, filed a similar petition to quash on June 10, 1983. The summonses at issue are third-party recordkeeper summonses issued pursuant to 26 U.S.C. § 7609; the summonses were issued on May 20, 1983. Notice was given to petitioners on May 23, 1983. For the reasons outlined below, petitioners’ petition to quash summons is denied.
I
Neit…
2Cases cited8 opinions
- United States v. PowellSupreme Court of the United States · 1964
- United States v. LaSalle National BankSupreme Court of the United States · 1978
- United States v. BiscegliaSupreme Court of the United States · 1975
- United States of America and Ralph L. Guyette, Special Agent, Internal Revenue Service v. John B. HarringtonCourt of Appeals for the Second Circuit · 1968
- United States of America and Jon P. Heydt, Special Agent v. Citizens State Bank, United States Taxpayers Union and Armin MothsCourt of Appeals for the Eighth Circuit · 1980
3 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- David J. Middleton and June C. Middleton v. United States of America and Albert Yandek, Revenue OfficerCourt of Appeals for the Sixth Circuit · 1986