United States of America and Vincent Mercugliano, Special Agent, Internal Revenue Service v. First Bank

PIERCE, Circuit Judge:

The United States of America and Vincent Mercugliano, Special Agent of the Internal Revenue Service (alternatively referred to collectively as the “Government”), appeal from an order of the United States District Court for the District of Connecticut, Ellen Bree Burns, Judge, entered September 27, 1983, denying a petition to enforce an Internal Revenue Service (“IRS”) summons served upon First Bank, a third-party recordkeeper, because the co-owner of the records summoned had not been given notice.

For the reasons set forth below, we reverse.

I. BACKGROUND

The facts relevant…