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UNITED STATES v. CHASE MANHATTAN BANK, N.A.

No. M-18-304.

584 F.Supp. 1080 (1984)

The UNITED STATES of America, et al., Petitioners, v. The CHASE MANHATTAN BANK, N.A., et al., Respondents.

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

March 27, 1984.

Attorney(s) appearing for the Case

Rudolph Giuliani, U.S. Atty. for the Southern Dist. of N.Y., New York City, for petitioner; Jonathan A. Lindsey, Asst. U.S. Atty., of counsel.

Milbank, Tweed, Hadley & McCloy, New York City, for respondent Chase Manhattan Bank, N.A.; William H. Roth, New York City, of counsel.

Patton, Boggs & Blow, Washington, D.C., for respondent F.D.C. Co., Ltd.; Allan Abbot Tuttle, George M. Borababy, Domenico De Sole, Washington, D.C., of counsel.

OPINION

GOETTEL, District Judge:

Before the Court is a petition to enforce a summons issued by the Internal Revenue Service ("the IRS"), by which it seeks to obtain the banking records of F.D.C. Co., Ltd. ("FDC"), a Hong Kong corporation, that are now in the custody and control of a Hong Kong branch of Chase Manhattan Bank, N.A. ("Chase"). The IRS seeks the records in connection with its investigation of Aldo Gucci and Gucci Shops, Inc. (hereinafter referred...

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