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and Camaro filed a petition to quash the nine summonses (the
Alabama petition to quash) in the U.S. District Court for the
Northern District of Alabama (the Alabama District Court) on
October 10, 1990.
Respondent served four more third-party administrative
summonses relating to petitioners’ and Camaro’s tax liabilities
for the 1983-89 tax years in October 1990. Around October 29,
1990, petitioners and Camaro amended the Alabama petition to
quash to include the four additional third-party summonses.
On April 29, 1991, the Alabama District Court denied the
Alabama petition to quash as to 12 of the 13 summonses. On June
10, 1991, the Alabama District Court granted the petition with
respect to one of the summonses.
2. Proceedings in the U.S. District Court for the Southern
District of New York
On October 11, 1990, respondent served a third-party
recordkeeper summons on SCB, directing the production of certain
documents relating to petitioners’ and Camaro’s tax liabilities
for the 1983-89 tax years. On October 12, 1990, respondent
served summonses on the Hongkong Bank (the HKB summons) and on
HSBC (the HSBC summons) relating to petitioners’ and Camaro’s tax
liabilities for the 1983 through 1989 tax years.
On November 2, 1990, SCB's attorneys responded to the SCB
summons but did not produce the records identified in the
summons.
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