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UNITED STATES v. MORGAN GUARANTY TRUST CO.

No. M-18-304 (CBM).

524 F.Supp. 24 (1981)

UNITED STATES of America and William C. VanShufflin, Special Agent, Internal Revenue Service, Petitioners, v. MORGAN GUARANTY TRUST CO. and Bank of New York, Respondents, and Leonard D. Summa, Intervenor.

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

February 25, 1981.

Attorney(s) appearing for the Case

John S. Martin, Jr., U.S. Atty., S.D.N.Y. by Susan M. Campbell, Asst. U.S. Atty., New York City, for petitioners.

Leonard D. Summa, pro se.

MEMORANDUM OPINION

MOTLEY, District Judge.

Respondents, Morgan Guaranty Trust Company and Bank of New York, were ordered, upon the application of petitioners, United States of America and William C. VanShufflin, to show cause why they should not be compelled to comply with three Internal Revenue Service (IRS) summonses duly issued and served on respondents, pursuant to 26 U.S.C. §§ 7402(b) and 7604(a). Neither of the respondents appeared or opposed...

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