Legal Opinion
In re Howard
Court of Appeals for the Third Circuit
Decided December 23, 1963No. 14272PublishedCited by 1 opinion
1Opinion of the Court
HASTIE, Circuit Judge.
To facilitate an inquiry into a taxpayer’s possible persisting income tax liability, special agent William Ankron of the Internal Revenue Service, acting under authority of section 7602 of the 1954 Internal Revenue Code, signed and served on John Howard an administrative summons, requiring him to appear before Ankron at a stipulated time and place and to produce his business records and accounts for a period of four years, three of which were “closed years” in that the normal three-year statute of limitations had run against the assessment of tax deficiencies. Howard…
2Cases cited13 opinions
- Hale v. HenkelSupreme Court of the United States · 1906
- Go-Bart Importing Co. v. United StatesSupreme Court of the United States · 1931
- Raffaele v. Granger, Collector of Internal RevenueCourt of Appeals for the Third Circuit · 1952
- New Hampshire Fire Insurance v. ScanlonSupreme Court of the United States · 1960
- Rothensies v. UllmanCourt of Appeals for the Third Circuit · 1940
8 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Application of John A. Howard to Quash Summons Issued to Him by the Internal Revenue Service in Connection With His Tax Liability and to Vacate the Service in Connection With His Tax Liability and for a Temporary Stay of the Special Agents Hearing Pending Decision of the Application to Quash and Vacate. United States of AmericaCourt of Appeals for the Third Circuit · 1963