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UNITED STATES v. GARDNER STEEL CORP.

Civ. A. Nos. 83-1708, 83-1709.

587 F.Supp. 1486 (1984)

UNITED STATES of America, and Samuel J. Ruggiero, Special Agent of the Internal Revenue Service, Plaintiffs, v. GARDNER STEEL CORPORATION, Defendant, Bruce Pickel and Laren Pickel, Intervenors. UNITED STATES of America, and Samuel J. Ruggiero, Special Agent of the Internal Revenue Service, Plaintiffs, v. H. WOLFE IRON & METAL, CO., Defendant, Bruce Pickel and Laren Pickel, Intervenors.

United States District Court, W.D. Pennsylvania, Pittsburgh Division.

June 13, 1984.

Attorney(s) appearing for the Case

Patricia Scott-Clayton, Trial Atty., Tax Div., U.S. Dept. of Justice, Washington, D.C., Thomas A. Daley, Asst. U.S. Atty., Pittsburgh, Pa., for plaintiffs.

William C. McClure, Richard P. Joseph, Stanley DeGory, McClure & Watkins, P.C., Pittsburgh, Pa., for defendant.

OPINION

SIMMONS, District Judge.

In these cases, the IRS seeks to compel taxpayers' compliance with summonses served upon two closely held companies. In two related cases, this Court previously quashed third party summonses during an evidentiary hearing on the validity of the IRS investigation of the taxpayers. In the case sub judice, the taxpayers again assail the validity of IRS summonses, arguing that the summonses were issued in bad faith and are therefore...

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