United States v. Zakutansky

*683MEMORANDUM

BEAMER, District Judge.

This action was commenced by the filing of a petition to enforce an Internal Revenue summons against the two named defendants. Jurisdiction of the Court is based on Title 26, U.S.C. Sections 7602 and 7604(a)1 and is unchallenged by the parties to the proceedings. The summons sought to be enforced against the defendants, seeks the production of accountant’s work papers used by defendant Zakutansky in preparing the income tax returns of Mr. Johnston for the years 1960 through 1965. At the time the action was commenced, respondent Johnston, the taxpayer, had…