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UNITED STATES v. SCHOENDORF

No. 69-C-56.

307 F.Supp. 1034 (1970)

UNITED STATES of America and Roy R. Koch, Special Agent, Internal Revenue Service, Petitioners, v. Joseph F. SCHOENDORF, Sr., and Joseph F. Schoendorf, Jr., Respondents, v. Thomas J. SCHOENDORF, Intervenor.

United States District Court E. D. Wisconsin.

January 12, 1970.

Attorney(s) appearing for the Case

Robert J. Lerner, U. S. Atty., by Roch Carter, Asst. U. S. Atty., Milwaukee, Wis., and James H. Jeffries III, Trial Atty., Tax Div., U. S. Dept. of Justice, Washington, D. C., for petitioners.

Joseph F. Schoendorf, Jr., Milwaukee, Wis., for respondents.

Robert E. Meldman, Milwaukee, Wis., for intervenor.

OPINION AND ORDER

REYNOLDS, District Judge.

This action was brought by the United States and Roy R. Koch, a Special Agent of the Internal Revenue Service ("IRS"), pursuant to §§ 7402(b) and 7604(a) of the Internal Revenue Code of 1954, to compel compliance with two Internal Revenue summonses. The summonses were issued to the respondents by Koch on October 10, 1968, and seek information concerning transactions between respondents and the taxpayer...

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