United States v. First National Bank of Chicago
United States Court of Appeals for the Seventh Circuit
699 F.2d 341 (1983)
- Written by Elizabeth Yingling, JD
Facts
The Internal Revenue Service (IRS) (plaintiff) served a subpoena on the First National Bank of Chicago (FNB) (defendant) for taxpayers’ banking records maintained in an FNB branch office in Greece. FNB refused to comply with the subpoena, arguing that the disclosure of the information would violate Greece’s criminal laws and subject FNB employees to imprisonment. FNB did disclose, however, that the taxpayers had only one account in the FNB Greek branch and the account held approximately $1,100. The purpose of the IRS subpoena was to collect on a tax liability of the taxpayers that had already been determined as due and owing. The IRS brought suit to enforce the subpoena. The district court ordered enforcement of the subpoena, and FNB moved to vacate the order.
Rule of Law
Issue
Holding and Reasoning (Fairchild, J.)
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