Legal Opinion
United States v. McGuirt
Court of Appeals for the Fourth Circuit
Decided December 4, 1978No. Nos. 77-1816, 77-2177PublishedCited by 11 opinions
1Opinion of the Court
K. K. HALL, Circuit Judge:
These appeals were consolidated because the primary issue presented in both is whether a summons issued by the Internal Revenue Service (IRS) is enforceable if it was issued in aid of an IRS criminal fraud investigation.
We delayed determination of this issue until the Supreme Court decided United States v. LaSalle National Bank, 437 U.S. 298, 98 S.Ct. 2357, 57 L.Ed.2d 221 (1978). The holding in LaSalle adopted the position taken by the IRS in both these cases: an internal revenue summons is enforceable if issued before the IRS recommends to the Department of Justice…
2Cases cited5 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. McCarthyCourt of Appeals for the Third Circuit · 1975
- United States v. Morgan Guaranty Trust Company, and Roger L. Keech and Sandra J. Keech, Intervenors-AppellantsCourt of Appeals for the Second Circuit · 1978
- United States of America and Ronald R. Taylor, Special Agent, Internal Revenue Service v. Sidney W. RosinskyCourt of Appeals for the Fourth Circuit · 1977
3Cited by11 opinions
- State v. BenoWisconsin Supreme Court · 1984
- United States v. MoonCourt of Appeals for the Eighth Circuit · 1980
- Godwin v. United StatesDistrict Court, D. Delaware · 1983
- United States of America and W. Donald Bell, Special Assistant, Internal Revenue Service v. The Equitable Trust Company, and Victor DivivoCourt of Appeals for the Fourth Circuit · 1979
- Uhrig v. United StatesDistrict Court, D. Maryland · 1984
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