PEOPLES DEPOSIT BANK & TRUST CO., PARIS, KY.
v.
UNITED STATES
AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.
The court held that the special agent's suspicion of fraudulent tax returns was sufficient to justify the district court's order compelling the bank to produce records.
A special agent of the IRS issued a summons to a bank to produce records related to the tax liability of certain individuals. The bank appealed the di…
The full statement of facts, procedural history, and disposition for this case are member content.
Join FLexlaw to unlock all legal intelligence© FLexlaw, Inc. — AI-generated enrichments are proprietary. All rights reserved.
PER CURIAM.
The appellant bank appeals from the District Court’s judgment requiring it to obey a summons issued by a special agent of the Bureau of Internal Revenue, in pursuance of section 3614 of the Internal Revenue Code, 26 U.S.C. § 3614, to appear and produce for inspection .and examination certain books, records, papers, and memoranda of the bank evidencing transactions occurring in the years 1944, 1945, and 1946, relating to the tax liability of E. F. Prichard, Sr., Aliene Power Prichard, E. F. Prichard, Jr., and Lucy Prichard.
At the hearing on the District Court’s order directing the appellant bank to show cause why it should not be punished for contempt of court in failing to obey the summons, a special .agent of the Bureau of Internal Revenue testified in substance, that from his investigation he had concluded that there was strong suspicion of a false or fraudulent tax return by E. F. Prichard, Sr., for a certain year or years prior to the statutory limitation. See sections 275, 276, Internal Revenue Code, 26 U.S.C. §§ 275, 276. The special agent was not obliged to disclose in detail the facts relative to his investigation and conclusion, nor was the District Court obliged to require proof of facts showing reasonable grounds to believe that the tax returns of E. F. Prichard, Sr., and others were false or fraudulent.
The testimony of the special agent clearly justified the District Court’s judgment requiring the appellant bank to obey the summons to appear and produce the books, records, papers, and memoranda in question. Section 3633, Internal Revenue Code, 26 U.S.C. § 3633. For the reasons stated in the opinion below, D.C., 112 F.Supp. 720, the judgment is affirmed.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By (13 total)
-
Boren v. Tucker, 239 F.2d 767 (9th Cir. 1956)
-
Foster v. United States, 265 F.2d 183 (2d Cir. 1959)
-
DE Masters v. Egon D. Arend and Mela K. Arend, 313 F.2d 79 (9th Cir. 1963)
Previewing 3 of 13 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligence