Uhrig v. United States

FRANK A. KAUFMAN, Chief Judge.

Pending before this Court are the petitions of Edward 0. Uhrig (“Taxpayer”) filed pursuant to 26 U.S.C. § 7609(b), to quash two Internal Revenue Service (“IRS”) summonses 1 and the cross motion of the United States for summary denial of Taxpayer’s petitions to quash and for summary enforcement of the two summonses under 26 U.S.C. § 7609(h).

The relevant facts in this case are not in dispute. On April 10, 1983 and July 6, 1983, Woodland R. Morris, a special agent with the IRS, issued summonses to the First National Bank of Maryland and to Prudential Bache,…