Legal Opinion

United States v. First National State Bank

Court of Appeals for the Third Circuit

Decided February 13, 1980No. Nos. 79-1707, 79-1708PublishedCited by 11 opinions

1Opinion of the Court

OPINION OF THE COURT

GARTH, Circuit Judge.

In these cross-appeals, we are again presented with a challenge to the enforcement of Internal Revenue Service (I.R.S.) summonses directed to third-party record-keepers. The taxpayer-intervenor (Levey) appeals at No. 79-1708 from the district court’s order which granted enforcement *670with respect to most of the documents requested. The Government appeals at No. 79-1707 from the district court’s refusal to order production of retained copies of forms 1099 and 1087. In light of our recent opinion in United States v. Garden State National Bank, 607 F.2d 61…

2Cases cited10 opinions

  1. United States v. PowellSupreme Court of the United States · 1964
  2. United States v. LaSalle National BankSupreme Court of the United States · 1978
  3. PAAC v. RizzoCourt of Appeals for the Third Circuit · 1974
  4. United States v. Garden State National BankCourt of Appeals for the Third Circuit · 1979
  5. United States v. TheodoreCourt of Appeals for the Fourth Circuit · 1973

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3Cited by11 opinions

  1. Townsend v. Columbia OperationsCourt of Appeals for the Ninth Circuit · 1982
  2. United States v. Roderick J. MacKenzie Malcolm L. MacKenzie and David H. MacKenzie Inc.Court of Appeals for the Second Circuit · 1986
  3. Green v. Internal Revenue ServiceDistrict Court, N.D. Indiana · 1982
  4. Interstate Commerce Commission v. James R. Gould, Doing Business as Brokers for Agricultural CooperativeassociationsCourt of Appeals for the Third Circuit · 1980
  5. United States of America and John R. Cassie, Jr., Special Agent, Internal Revenue Service v. First National State Bank of New Jersey, Perry Levey, Intervenor. United States of America and John R. Cassie, Jr., Special Agent, Internal Revenue Service v. Berkeley Federal Savings and Loan Association, Perry Levey, Intervenor. United States of America and John R. Cassie, Jr., Special Agent, Internal Revenue Service v. Hudson City Savings Bank, Perry Levey, Intervenor. United States of America and John R. Cassie, Jr., Special Agent, Internal Revenue Service v. Livingston National Bank, Perry Levey, IntervenorCourt of Appeals for the First Circuit · 1980

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