United States of America and W. Donald Bell, Special Assistant, Internal Revenue Service v. The Equitable Trust Company, and Victor Divivo

KAUFMAN, District Judge.

This case involves an administrative summons issued by the Internal Revenue Service (IRS) pursuant to 26 U.S.C. § 7602 to *494require the Equitable Trust Company (Equitable), a Baltimore banking institution, to provide all records held by the latter relating to a mortgage loan made by it to DiVivo, Intervenor herein, and DiVivo’s business associate, DiBiasi, in their capacities as individuals trading as Italian Delight Restaurant. The summons is sought in furtherance of a tax investigation of DiBiasi, not DiVivo, but specifically refers to “records * * * with respect to a…