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UNITED STATES v. WILLIAMS

No. M-18-304.

337 F.Supp. 1114 (1971)

UNITED STATES of America, Petitioner, v. Allen WILLIAMS, Executive Director of the New York State Psychological Association, Inc., 145 East 52nd Street, New York, New York, Respondent. v. Rudolph Wittenberg, Intervenor.

United States District Court, S. D. New York.

December 15, 1971.

Attorney(s) appearing for the Case

Whitney North Seymour, Jr., U. S. Atty., by Peter Alan Herbert, Asst. U. S. Atty., New York City, for petitioner.

C. Stewart Dickert, Mariano, Lloyd & Dickert, New York City, for respondent.

Jay H. Topkis, Neil H. Cogan, Paul, Weiss, Goldberg, Rifkind, Wharton & Garrison, New York City, for intervenor.

MOTLEY, District Judge.

Memorandum Opinion

The government petitions pursuant to 26 U.S.C. §§ 7402(b) and 7604(a) to enforce an Internal Revenue Service summons issued for the purpose of determining the tax liability of intervenor Rudolph Wittenberg for the years 1966, 1967 and 1968. In 1969, as a result of an independent investigation, the IRS claims to have discovered that certain checks paid...

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