United States v. First Pennsylvania Bank

MEMORANDUM

RAYMOND J. BRODERICK, District Judge.

This is a proceeding instituted by a complaint filed by the Internal Revenue Service (IRS) to enforce a summons served on the defendant, First Pennsylvania Bank (Bank), 1 calling for the production of specified books and records concerning the tax liability of Daniel J. Callahan (Mr. Callahan) for the years 1973 and 1974. 2 A show' cause hearing was held on July 28, 1977, at which time Mr. Callahan filed a pro se motion to intervene. This Court granted the taxpayer’s motion to intervene for the purpose of affording him an opportunity to set forth…