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UNITED STATES v. HILL

Nos. CA 3-81-0879-C, CA 3-81-0936-C.

537 F.Supp. 677 (1982)

UNITED STATES of America and Buford E. Gamblin v. Paul HILL, Controller, First International Bancshares, Inc.

United States District Court, N. D. Texas, Dallas Division.

April 13, 1982.

Attorney(s) appearing for the Case

James A. Rolfe, U. S. Atty., Dallas, Tex., for plaintiffs.

Ernest E. Figari, Jr., Richard C. Stark, Johnson, Swanson & Barbee, Dallas, Tex., for defendant.

Wm. H. Smith, Gen. Counsel, Johanna M. Sabol, Associate Counsel, Michael F. Crotty, Asst. Counsel, Litigation, Washington, D. C., for amicus curiae American Bankers Ass'n.

H. Gene Emery and Allen Sparkman, Rain, Harrell, Emery, Young & Doke, Dallas, Tex., for amicus curiae Republic of Tex. Corp.

OPINION

WILLIAM M. TAYLOR, Jr., District Judge.

These are summons enforcement actions under § 7604(a) of the Internal Revenue Code of 1954 (26 U.S.C. § 7604(a)).1

Respondent defends on essentially two grounds. The first is that Petitioner has not complied with the Right to Financial Privacy Act, 12 U.S.C. § 3401 et seq. The second is that Petitioner does not seek information relevant to his audit...

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