United States v. Bank of Moulton

During an investigation of the federal. tax liability for 1974-77 of James W. Roberts and Carolyn Roberts, Special Internal Revenue Service' Agent James S. Rogers served a summons1 on the Bank of Moulton and on its vice president, Robert C. Henderson. Issued and served on June 30, 1978, the summons directed these third-party recordkeepers to give testimony and produce bank documents relevant to the inquiry into the Roberts’ tax liability on July 18, 1978. On July 12, the Roberts gave timely notice to the bank not to comply with the summons under 26 U.S.C. § 7609(d)(1) (1976). This provision…