United States of America and T. B. Schopfer, Revenue Officer, Internal Revenue Service v. C. H. Harper

The taxpayer appeals from the district court’s enforcement of an Internal Revenue Service summons directing him to appear before a revenue officer to testify and to produce certain documents and records relating to his financial status.1 The taxpayer had been assessed for certain penalties and interest relating to the years 1969 through 1971, and the summons had the legitimate purpose of aiding in determining the collectibility of the liability in question.

The taxpayer asserts that his tax liability for the years in question has been conclusively determined by a proceeding in the bankruptcy…