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UNITED STATES v. MERRELL

Civ. No. Misc.

303 F.Supp. 490 (1969)

UNITED STATES of America and Patrick C. Putney, Special Agent, Internal Revenue Service, Petitioners, v. Edgar S. K. MERRELL, II, Respondent.

United States District Court N. D. New York.

July 9, 1969.

Attorney(s) appearing for the Case

Paul R. Shanahan, Syracuse, N. Y., for taxpayer-movant.

Justin J. Mahoney, U. S. Atty., Albany, N. Y., for United States and Putney, James P. Shanahan, Syracuse, N. Y., of counsel.

MEMORANDUM-DECISION AND ORDER

PORT, District Judge.

The factual background in this case is relatively simple. The taxpayers, Raymond B. and Eleanor E. Lee, retained Edgar S. K. Merrell, II, an attorney, to prepare for them their federal tax returns for the years 1957-66 inclusive. In connection with this, the taxpayers provided Merrell with various documents, including records of income and expenses, and other papers necessary for the preparation of their...

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