Legal Opinion
Schott v. Secretary of Treasury
District Court, N.D. Ohio
Decided September 27, 1995No. 1:95CV1463Published
1Opinion of the Court
*507 MEMORANDUM OF OPINION
MANOS, District Judge.
On June 30,1995, John F. Schott, the petitioner,1 filed the above captioned ease against the Secretary of the Treasury, the Internal Revenue Service (IRS), the Attorney General of the United States, the United States Attorney for the Northern District of Ohio, (collectively, the Government), and Dollar Bank (the Bank), the respondents, seeking to quash an IRS summons issued to the Bank. Jurisdiction is predicated upon 26 U.S.C. §§ 7402(b), 7604(a).
On August 28, 1995, the Government filed a motion to dismiss. On September 15,1995, Schott responded.2…
2Cases cited7 opinions
- Conley v. GibsonSupreme Court of the United States · 1957
- Scheuer v. RhodesSupreme Court of the United States · 1974
- United States v. PowellSupreme Court of the United States · 1964
- Sam Williams v. Dwight Browman Grant Harris Daniel BarnesCourt of Appeals for the Sixth Circuit · 1992
- Roger Sylvestre v. United States of AmericaCourt of Appeals for the First Circuit · 1992
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