Legal Opinion
Roger Sylvestre v. United States of America
Court of Appeals for the First Circuit
Decided October 30, 1992No. 92-1636PublishedCited by 28 opinions
1Per curiam
On April 14, 1992, the IRS issued and served a summons to each of 3 banks as third party recordkeepers, seeking records of savings accounts, checking accounts, and the like, pertaining to Roger Sylvestre. Pursuant to 26 U.S.C. § 7609, Sylvestre is entitled to notice of a third party summons and may petition to quash such a summons. Sylvestre was given notice and did, in fact, seek to quash each of the 3 summonses. The IRS objected to the petition to quash and sought enforcement of the summonses. After a hearing, the district court denied the petition to quash and granted enforcement of the…
2Cases cited10 opinions
- United States v. Ilario M.A. ZanninoCourt of Appeals for the First Circuit · 1990
- United States v. PowellSupreme Court of the United States · 1964
- United States v. LaSalle National BankSupreme Court of the United States · 1978
- United States v. SalterCourt of Appeals for the First Circuit · 1970
- United States of America and Anthony Carsanaro, Revenue Agent, Internal Revenue Service v. The Freedom Church and Reverend Richard M. DoncasterCourt of Appeals for the First Circuit · 1979
5 more not listed; retrieve them via the Exa API.
3Cited by28 opinions
- United States v. RicheyCourt of Appeals for the Ninth Circuit · 2011
- United States v. Nancy Gertner, Etc., John Doe, IntervenorCourt of Appeals for the First Circuit · 1995
- United States v. Insurance Consultants of Knox, Incorporated, and Marvin D. MillerCourt of Appeals for the Seventh Circuit · 1999
- Thomas M. Cook and Carol L. Cook v. United StatesCourt of Appeals for the Sixth Circuit · 1997
- Adamowicz v. United StatesCourt of Appeals for the Second Circuit · 2008
23 more not listed; retrieve them via the Exa API.