Legal Opinion
Liberty Financial Services and First Capital Securities, Inc. v. United States
Court of Appeals for the First Circuit
Decided December 18, 1985No. 84-2267PublishedCited by 52 opinions
1Per curiam
Liberty Financial Services (“Liberty”) appeals the district court’s denial of its petition to quash IRS summons and the entry of summary judgment in favor of the United States. We affirm.
The United States, through the Internal Revenue Service (“IRS”), instituted an investigation to determine whether Liberty had engaged in promoting abusive tax shelters subjecting it to liability for penalties imposed by 26 U.S.C. § 6700 (1967). In conjunction with this investigation, the IRS served a third-party recordkeeping summons on Wells Fargo Bank, pursuant to the provisions of 26 U.S.C. § 7609 (1976),…
2Cases cited6 opinions
- United States v. PowellSupreme Court of the United States · 1964
- United States v. GarrettCourt of Appeals for the Fifth Circuit · 1978
- United States v. KisCourt of Appeals for the Seventh Circuit · 1981
- Tiffany Fine Arts, Inc. v. United StatesSupreme Court of the United States · 1985
- United States v. Balanced Financial Management, Inc.Court of Appeals for the Tenth Circuit · 1985
1 more not listed; retrieve them via the Exa API.
3Cited by52 opinions
- United States v. JoseCourt of Appeals for the Ninth Circuit · 1997
- United States v. Dynavac, Inc.Court of Appeals for the Ninth Circuit · 1993
- United States v. Nancy Gertner, Etc., John Doe, IntervenorCourt of Appeals for the First Circuit · 1995
- United States v. ZolinCourt of Appeals for the Ninth Circuit · 1987
- United States of America Charles L. Gresham, Revenue Officer of the Internal Revenue Service v. David O. Saunders and Sharon SaundersCourt of Appeals for the Ninth Circuit · 1991
47 more not listed; retrieve them via the Exa API.