United States v. Lester Genser and Lawrence Forman

OPINION OF THE COURT

SEITZ, Chief Judge.

In this aspect of these appeals we must examine the substantive and procedural implications of the Supreme Court’s decision in United States v. LaSalle National Bank, 437 U.S. 298, 98 S.Ct. 2357, 57 L.Ed.2d 221 (1978), which described the limits of the Internal Revenue Service’s authority to issue civil summonses under 26 U.S.C. § 7602. Defendants Lester Genser and Lawrence Forman appealed from their convictions for tax evasion. In an earlier opinion we rejected various challenges to those convictions but retained jurisdiction and remanded the case to…