MATTER OF DOES

Misc. No. 646.

541 F.Supp. 213 (1982)

In the Matter of the Tax Liabilities of John DOES, Unidentified Clients and Customers Who Invested or Participated in Dairy Cattle Programs Promoted by Agricultural Asset Management Co., Inc., in the years 1978, 1979, and 1980.

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

April 19, 1982.


Attorney(s) appearing for the Case

Hinman, Straub, Pigors & Manning, P. C., Albany, for Ag. Asset, Inc.; Leslie M. Apple, Albany, N. Y., of counsel.

George H. Lowe, U. S. Atty., Syracuse, N. Y., Glenn L. Archer, Jr., Asst. Atty. Gen., Tax Div., U. S. Dept. of Justice, Washington, D. C., for the U. S., William P. Fanciullo, Asst. U. S. Atty., Albany, N. Y., Matthew Yackshaw, Trial Atty., Tax Div., Washington, D. C., of counsel.


MEMORANDUM-DECISION and ORDER

MINER, District Judge.

I.

On January 19, 1982, the United States filed a petition for leave to serve a third party John Doe summons upon Agricultural Asset Management Co., Inc. (hereinafter "Ag Asset") and Mr. Jeffrey Adler, Ag Asset's treasurer. The petition was filed pursuant to 26 U.S.C. §§ 74021 and 7609(f)2 and was properly supported with a memorandum...

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