Legal Opinion
Bisceglia v. United States
Court of Appeals for the Sixth Circuit
Decided October 18, 1973No. 72-1783PublishedCited by 7 opinions
1Opinion of the Court
McCREE, Circuit Judge.
This appeal requires us to determine whether the Internal Revenue Service may use a civil summons to compel a third party to produce for examination records pertaining to the financial affairs of unspecified and unidentified persons and organizations for the purpose of ascertaining their identities. We hold that it may not.
The facts of the case are not disputed. On November 6, 1970, and on November 16, 1970, the Cincinnati branch of the Federal Reserve Bank of Cleveland received deposits of currency from the Commercial Bank of Middlesboro, Kentucky. Each deposit included…
2Cases cited11 opinions
- Donaldson v. United StatesSupreme Court of the United States · 1971
- Paul W. Tillotson, Special Agent, Internal Revenue Service v. Jackson L. BoughnerCourt of Appeals for the Seventh Circuit · 1965
- United States v. TheodoreCourt of Appeals for the Fourth Circuit · 1973
- First Nat. Bank of Mobile v. United StatesCourt of Appeals for the Fifth Circuit · 1947
- Local 174, International Brotherhood of Teamsters, Chauffeurs, Warehousemen and Helpers of America and Nugent La Poma v. United StatesCourt of Appeals for the Ninth Circuit · 1956
6 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Robert Hawthorne, Inc. v. Director of Internal RevenueDistrict Court, E.D. Pennsylvania · 1976
- United States of America and Albert J. Valentas, Internal Revenue Agent v. Humble Oil & Refining CompanyCourt of Appeals for the Fifth Circuit · 1974
- United States v. Continental Bank & Trust Co.Court of Appeals for the Tenth Circuit · 1974
- United States of America and Lawrence H. Pennington, Special Agent, Internal Revenue Service v. Arnold Berkowitz and a & M Berk Tax Service, Inc.Court of Appeals for the Third Circuit · 1973
- United States v. Continental Bank & Trust CompanyCourt of Appeals for the Tenth Circuit · 1974
2 more not listed; retrieve them via the Exa API.