Legal Opinion

United States v. Bonnell

District Court, D. Minnesota

Decided December 27, 1979No. Civ. 4-78-190, 4-78-191PublishedCited by 19 opinions

1Opinion of the Court

MEMORANDUM AND ORDER

MacLAUGHLIN, District Judge.

These cases present novel and difficult issues regarding the enforceability of certain tax summonses 1 issued by the Internal Revenue Service (hereinafter “the IRS”). The summonses require the production of documents and the giving of testimony by and from Cargill, Inc., Charles Rice, Assistant Vice President of Cargill, Inc., Cargill’s certified public accountants, Peat, Marwick, Mitchell & Co. (hereinafter “PMM”) and Harold Bonnell, a partner in PMM.

Cargill resists the enforcement of the summonses on the ground that they are predicated upon a…

2Cases cited79 opinions

  1. Bivens v. Six Unknown Named Agents of Federal Bureau of NarcoticsSupreme Court of the United States · 1971
  2. Wong Sun v. United StatesSupreme Court of the United States · 1963
  3. United States v. WadeSupreme Court of the United States · 1967
  4. Hickman v. TaylorSupreme Court of the United States · 1947
  5. Stone v. PowellSupreme Court of the United States · 1976

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3Cited by19 opinions

  1. United States v. DavisCourt of Appeals for the Fifth Circuit · 1981
  2. National Tank Co. v. BrothertonTexas Supreme Court · 1993
  3. Federal Trade Commission v. Trw, Inc. And Its Unincorporated Division, Trw Credit DataCourt of Appeals for the D.C. Circuit · 1980
  4. Towne Place Condo. Ass'n v. Phila. Indem. Ins. Co.District Court, E.D. Illinois · 2018
  5. Bituminous Casualty Corp. v. Tonka Corp.District Court, D. Minnesota · 1992

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