UNITED STATES v. GENSER, 582 F.2d 292 (3rd Cir. 1978)

UNITED STATES OF AMERICA, APPELLEE, v. LESTER GENSER AND LAWRENCE FORMAN, APPELLANTS.

Nos. 76-2623 and 76-2624.

United States Court of Appeals, Third Circuit.

Argued October 4, 1977.

Decided August 29, 1978.

 

Headnotes 1

[1] OPINION OF THE COURT – BIGGS, Circuit Judge. 2

I. [ ] 2

II. [ ] 4

III. [ ] 7

IV. [ ] 9

Footnotes 22

End of document 32

Headnotes

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[EDITORS' NOTE: THIS PAGE CONTAINS HEADNOTES. HEADNOTES ARE NOT AN

OFFICIAL PRODUCT OF THE COURT, THEREFORE THEY ARE NOT DISPLAYED.]

Page 294

Irving R. Segal, Herbert S. Mednick, James D. Fornari,

Schnader, Harrison, Segal & Lewis, Philadelphia, Pa., for

appellants; Zuckerman & Aronson, Newark, N. J., of counsel.

John J. Barry, Asst. U.S. Atty., Jonathan L. Goldstein, U.S.

Atty., Maryanne T. Desmond, Asst. U.S. Atty., Appeals Div.,

Newark, N. J., for appellee.

Appeal from the United States District Court for the District

of New Jersey.

Before SEITZ, Chief Judge, and BIGGS and HUNTER, Circuit

Judges.

[1] OPINION OF THE COURT – BIGGS, Circuit Judge.

[2] The appellants, defendants below, Genser and Forman, appeal

from their convictions by a jury for violations of 18 U.S.C. §§

2, 371, and 26 U.S.C. §§ 7201, 7206(1). The indictment charged

both appellants with conspiracy to evade personal and corporate

income taxes, and with the substantive crimes of evading

corporate and personal income taxes, and subscribing to corporate

tax returns which understated their adjusted gross income. The

appeals were consolidated pursuant to the rules of this court and

are properly before us pursuant to 28 U.S.C. § 1291.

[3] The appellants assert (1) that there is insufficient evidence

to support their convictions on the personal income tax charges;

(2) that the trial court erred in permitting an agent of the

Internal Revenue Service to testify as to the results of an audit

of their corporation's books, which audit the agent did not

conduct or supervise and which was not introduced into evidence;

and (3) that the United States procured some of its evidence

illegally by administrative summonses

Page 295

pursuant to 26 U.S.C. § 7602, and that the district court

erred in not granting an evidentiary hearing. They contend that

such a hearing would have demonstrated that the administrative

summonses were issued after the United States had formed an

intention to prosecute the appellants for income tax evasion and

fraud, and that therefore the evidence procured by the summonses

was tainted and should have been suppressed, and a new trial

granted.

I.

[4] Lawrence Forman and Lester Genser were, respectively, the

president and vice president of Genser-Forman, Inc. (Corporation)

from 1957 until early 1973. The Corporation was the sole

distributor in the northeastern United States of Triumph cars and

parts for British Leyland Motors, Inc. (British Leyland) until

the Corporation was dissolved in 1973. The Corporation bought

cars and parts from British Leyland and resold them to a network

of automobile dealers located in its exclusive area of

distribution. From 1969 to 1973, the years encompassed by the

indictment, the Corporation purchased and imported approximately

6000 cars per year from British Leyland.

[5] By contractual agreement between the Corporation and British

Leyland, British Leyland bore all of the expenses of repair to

"marine damage" to the cars occurring during their transportation

from England to the United States. Although initially British

Leyland reimbursed the Corporation for its actual repair expenses

in accordance with an appraiser's estimate, after 1966 it

followed a policy of paying the Corporation a fixed marine damage

reimbursement of $36.00 for every Triumph delivered to the

Corporation. In addition, British Leyland reimbursed the

Corporation for repairs done by the Corporation under warranty,

for obsolete parts returned to British Leyland by the

Corporation, for discontinued models of automobiles remaining in

inventory, for one-third of the Corporation's advertising costs,

and for part of the rental expenses of a New York City showroom.

Dealers to whom the Corporation distributed Triumph cars

reimbursed the Corporation for its transportation expenses.

[6] The charges brought against appellants stem from their handling

of these funds. From 1967 until early 1973, the moneys received

from British Leyland and the Triumph dealers were deposited,

pursuant to the directions of Genser and Forman, in a corporate

account maintained in the name of Genser-Forman, Inc., in the

City National Bank of Hackensack (Hackensack Account). These

funds were kept separately from other funds of the Corporation,

which were kept in the First National State Bank, Millburn-Short

Hills Branch. Genser and Forman were the only signatories on the

Hackensack Account.

[7] From 1969 to 1973, the period encompassed by the indictment,

nearly $2,200,000, representing sums paid to the Corporation from

British Leyland and the dealers, was diverted to the Hackensack

Account. None of the Corporation's books and records, and none of

its tax returns, reflected any of these funds. Nor were the

Corporation's accountants aware that the Corporation had such

funds, either as income or as offsets to deducted expenses; the

accountants did not perform audits of the Corporation's expense

accounts and ledgers, but merely assembled books and records

prepared by the Corporation from which the Corporation's tax

returns were prepared. Had the accountants been aware of the

funds and the sources thereof, the funds would have either

increased the Corporation's cash account or decreased an expense

account, with the result that the Corporation's profits would

have been greater and its federal income tax liability larger.

The government calculated that for the years 1970 to 1973,

inclusive, the Corporation had an additional tax liability of

$884,487.02 and additional gross profits of $1,830,267.76.[fn1]

Page 296

[8] The funds deposited in the Hackensack Account were used by the

appellants to purchase a variety of tax-exempt municipal bearer

bonds through third party nominees. From 1969 to 1973, a total of

$2,084,975.34 — representing more than 100 bond transactions —

was withdrawn from the Hackensack Account to effectuate the

purchase of the bonds, which were kept in corporate safe deposit

boxes in the Millburn-Short Hills branch of the First National

State Bank. The books, records, and tax returns of the

Corporation never reflected the acquisition of the bonds, and the

Corporation's accountants were never informed that the bonds were

purchased. On the theory that the appellants had appropriated the

corporate moneys in the Hackensack account to their own use by

purchasing bonds for their own benefit, and that these moneys

thus represented unreported income to the appellants, the

government calculated that from 1969 to 1972, inclusive, Genser

had additional personal taxable income of $1,108,438.81 and

additional tax liability of $777,777.64, while Forman had

additional personal taxable income of $914,107.36 and additional

tax liability of $645,355.69.[fn2]

[9] In early 1973 British Leyland abandoned its distributorship

arrangement and bought out the Corporation. Following the

acquisition, the Corporation, pursuant to § 337 of the Internal

Revenue Code, liquidated and distributed all of its assets. As a

result of the liquidation all assets of the Corporation became

the sole and exclusive property of Genser and Forman and came

under their personal dominion and control between October 1972

and October 1973.

II.

[10] Appellants argue that the evidence was insufficient to support

their convictions on personal income tax evasion in that the

government failed to prove beyond a reasonable doubt that they

exercised personal dominion and control over the funds in the

Hackensack Account and the proceeds thereof (the bonds) prior to

the liquidation of the Corporation. Specifically, they contend

that the bulk of the government's proofs establish only that

appellants exercised personal dominion and control over the bonds

after the Corporation was liquidated (at which point, they

stress, the Corporation's assets were rightfully theirs),[fn3]

and that the government on the whole failed to show by

documentary evidence any exercise of personal dominion and

control prior to the Corporation's liquidation.

[11] Viewing the evidence, as we must, in the light most favorable

to the government, Glasser v. United States, 315 U.S. 60, 80,

62 S.Ct. 457, 86 L.Ed. 680 (1942), we think that the evidence is

sufficient to secure appellants' convictions. Rather than detail

all the evidence presented on this issue, we think it sufficient

to cite the following in support of our conclusion:

[12] (1) More than 100 bond purchase transactions were paid for with

funds from the

Page 297

Hackensack Account. Virtually all these purchases were tied back

to the Hackensack bank statements by the amount appearing on the

bond purchase documentations, which also indicated the types of

bonds acquired and the serial numbers. The government also

introduced coupon collection letters (Exhibit G-26), which

recorded bond coupon negotiations by the appellants prior to

liquidation of the Corporation. More than one-half of the

transactions were further linked to appellants by interest

coupons cashed or otherwise used by them or their relatives

bearing the same serial numbers as the bonds purchased with the

Hackensack moneys. Although, as appellants stress, the coupons

actually introduced at trial by the government were dated and

cashed at various times after liquidation, testimony

established that within one year after coupons have been

negotiated, they are destroyed by the paying agent, bank, or

issuing authority. We think that, considering the other evidence

of appellants' preliquidation dominion and control, reviewed

infra, the trial court did not abuse its discretion in

admitting coupons cashed after 1973, the only coupons which the

government could physically produce.

[13] To take but one example, the evidence shows that on March 26,

1971, four bonds, The Board of Education of the Township of

Union, New Jersey, serial numbers 723 through 726, were purchased

from Hanauer, Stern & Co. for $15,793.44. The Hackensack bank

statement recorded a withdrawal on March 30, 1971, of $15,793.44.

Each of the four bonds bore numerous coupons, each worth $102.50,

payable every six months. According to the coupon collection

letters, every six months, from 1971 onward, $410.00 (4 x

$102.50) was charged to appellants' personal account. Although

the collection letters contain the name of the depositor, the

issuing authority, and the value of the coupons, they do not list

the serial numbers of the coupons or bonds being negotiated.

Because, as stated, coupons are destroyed within one year after

negotiation, the only coupons physically produced by the

government in connection with these particular bonds were dated

February 1976, long after liquidation. Appellants thus argue that

due to the lack of serial numbers on the coupon collection

letters, and due to the lack of coupons cashed prior to

liquidation, the government failed to prove that coupons

negotiated by them prior to liquidation came from the specific

bonds purchased with Hackensack funds in 1971. However, we think

that in light of all the evidence introduced, this was a matter

for the jury.

[14] (2) The Corporation's tax returns from 1969 to 1973 failed to

reflect the existence of the Hackensack Account or the bonds

purchased therewith either in the asset column of the balance

sheet under "Government obligations" or in Schedule M-1, 7,

"Tax-exempt interest."

[15] (3) the manner in which the bonds were purchased suggests that

appellants did not regard them as Corporate property even at the

time of their purchase. Appellants' orders for bonds were placed

by third parties for customer's accounts which did not indicate

the customer's name. With respect to certain bonds purchased for

Genser through an officer of the City National Bank in

Hackensack, normal banking procedures regarding purchase and

delivery of the bonds apparently were not followed; although the

bank maintained a bound volume in which all bond purchases were

listed along with the purchaser's signatures, information

relative to Genser's purchases were kept in a separate file

maintained only for him. Moreover, several purchases were

apparently designed to be divided equally between Genser and

Forman; on numerous occasions, where two purchases of bonds from

the same issuer had slightly different purchase prices, a check

for the exact difference made payable to cash and signed by

Genser or Forman would be issued on the Hackensack Account in

order to equalize appellants' holdings. One purchase executed for

Genser in 1967 included a change of order slip directing the

investment company to split the purchase equally in two;

thereafter, both appellants negotiated coupons from this bond.

Page 298

[16] (4) Appellants concede that in 1970 or 1971, Richard Genser,

appellant Genser's son, received several $5000 New Jersey

Turnpike Authority bonds as a gift from his father. The bonds,

which bore serial numbers 11499-11507, were admitted into

evidence. Other evidence established that these bonds were

purchased with funds from the Hackensack Account in 1970. On July

15, 1975, Richard Genser cashed six $130 coupons, number 14 in

the coupon series, from these same bonds. Furthermore, Richard

Genser testified that in 1972 or 1973 he borrowed New Jersey

Turnpike Authority bonds, in the face amount of $30,000 or

$35,000, from his father as collateral for a loan at First

National State Bank. He indicated that he believed the bonds to

be the same type as those he had received as a gift from his

father in 1970 or 1971.

[17] (5) John Genser, another of appellant Genser's sons, testified

that between 1968 and 1970, he received coupons, totaling $4035

annually, from New York Port Authority bonds held by his father,

and that he, John, cashed the coupons and received the proceeds.

In 1973 or 1974 he received from his father the same bonds (with

a face value of $120,000) from which those coupons had been

clipped. The record shows that New York Port Authority bonds were

among those purchased with money from the Hackensack Account.

John Genser testified that he accompanied his father to the First

National Bank in Millburn on one occasion, and that his father

may have gotten the bonds there and later given them to him at

home.

[18] (6) Samuel Albanese, a bank officer at the First National State

Bank, Millburn-Short Hills branch, testified that (at an

unspecified time) proceeds of coupons were deposited by Genser in

his personal account at that bank. Bank records demonstrate that

prior to 1973 at least some of the deposits took place shortly

after Genser had access to the safety deposit boxes which were

maintained by the Corporation at the bank and which appellants

concede were used to store the bonds. The government produced

numerous coupons from bonds purchased with money from the

Hackensack Account, which were negotiated by Genser at the First

National Bank during 1975 and 1976.

III.

[19] The appellants argue that it was error for the trial judge to

allow Special Agent Dorgeval to testify as an expert witness

about his opinions concerning the results of an IRS audit of the

appellants' records, since Dorgeval did not participate in or

supervise the audit and the audit itself was not introduced into

evidence. Dorgeval testified, inter alia, that based upon his

own examination of the Corporation's books and records, the money

placed by the appellants into the Hackensack account constituted

unreported income. While the record is unclear as to whether

Dorgeval relied upon an audit conducted solely by other agents,

which audit was not admitted into evidence, assuming arguendo

that he had done so, his testimony would not have been rendered

inadmissible.

[20] Federal Rule of Evidence 703 states: "The facts or data in the

particular case upon which an expert bases an opinion or

inference may be those perceived by or made known to him at or

before the hearing. If of a type reasonably relied upon by

experts in the particular field in forming opinions or inferences

upon the subject, the facts or data need not be admissible in

evidence." Id. The testimony adduced from Dorgeval, even if

partially based upon hearsay, was in compliance with the rule.

The principal question is whether any out-of-court statements and

reports relied upon by the expert are such that he can reasonably

rely upon them and whether his reliance is reasonable under the

facts of the case. 3 Weinstein's Evidence, ¶ 703[03]; United

States v. Sims, 514 F.2d 147, 149 (9th Cir. 1975). We fail to

discern any abuse of discretion by the trial judge in allowing

Dorgeval to rely in part — if he did — upon the government audit

in reaching his conclusions, especially since the appellants

attack the reliability of the audit papers primarily on the

ground that IRS

Page 299

agents acted improperly in issuing administrative

summonses.[fn4]

[21] The appellants urge that because the audit papers were not

admitted into evidence and because the government did not use the

testimony of the agents who did prepare the audit, they were

denied the right to cross-examine the auditing agents'

conclusions and underlying documentation. However, the

confrontation clause does not by itself prohibit the use of

hearsay testimony. See California v. Green, 399 U.S. 149, 90

S.Ct. 1930, 26 L.Ed.2d 489 (1970). Rather, it focuses upon the

right of the accused to "`confront and probe each of his

accusers.'" United States v. Williams, 447 F.2d 1285, 1289 (5th

Cir. 1971) (footnote and citation omitted). Here, at the most,

Dorgeval was testifying to his own opinion, based upon the audit,

and the appellants had a full opportunity to confront his

opinions and reduce their impact in any manner available,

including questioning his reliance upon the audits without having

been involved in the auditing process himself. See Williams,

supra, at 1288-90.

[22] We conclude that no error was committed by the trial judge in

admitting Dorgeval's testimony.

IV.

[23] Appellants contend that portions of the evidence upon which

their convictions were based were obtained by means of illegally

issued Internal Revenue Service (IRS) administrative summonses

and thus should have been excluded by the trial court along with

the tainted fruits thereof. They also assign as error the trial

court's refusal to hold an evidentiary hearing to determine

whether the administrative summonses, served on third parties

pursuant to 26 U.S.C. § 7602, were issued in good faith and prior

to a recommendation of criminal prosecution.[fn5]

[24] Section 7602, 26 U.S.C. § 7602, permits the IRS to issue

summonses to persons to obtain testimony and documents for the

limited purpose "of ascertaining the correctness of any return,

making a return where none has been made, determining the

liability of any person for any internal revenue tax . . . or

collecting any such liability."[fn6] In Donaldson v. United

States,

Page 300

400 U.S. 517, 91 S.Ct. 534, 27 L.Ed.2d 580 (1971), the

Supreme Court, interpreting its earlier decision in Reisman v.

Caplin, 375 U.S. 440, 446, 84 S.Ct. 508, 11 L.Ed.2d 459

(1964), held that "under § 7602 an internal revenue summons may

be issued in aid of an investigation if it is issued in good

faith and prior to a recommendation for criminal prosecution."

Id. 400 U.S. at 536, 91 S.Ct. at 545. Accordingly, at several

stages during the proceedings below, appellants sought an

evidentiary hearing to determine whether the IRS had complied

with these requirements.[fn7] They contended that if the

summonses failed to meet the standards set forth in Donaldson,

any evidence used at trial which was acquired by means of the

summoned information should be suppressed. In denying the

appellants' motions to suppress and to hold an evidentiary

hearing, the trial judge ruled, inter alia, that appellants had

failed on the record to demonstrate any abuse of process and that

even if their allegations could be fully substantiated at an

evidentiary hearing, appellants lacked standing to assert their

claims under the principles recently announced in United States

v. Miller, 425 U.S. 435, 96 S.Ct. 1619, 48 L.Ed.2d 71

(1976).

[25] The question of whether or not a taxpayer has standing at trial

to attack the validity of a § 7602 summons issued to third

parties who voluntarily complied and to have the fruits of an

improper summons excluded from evidence has never been addressed

directly by this court or by the Supreme Court insofar as we are

aware. Previous decisions, of course, have established that the

person to whom a summons is issued, whether the taxpayer or a

third party, may refuse to comply with the summons, thereby

triggering judicial enforcement proceedings at which the legality

of the summons can be determined. Reisman v. Caplin, supra;

Donaldson v. United States, supra.[fn8] Where an administrative

summons is issued to a third party, such as the taxpayer's bank,

the taxpayer may attempt to restrain voluntary compliance by the

third party,[fn9] assuming that he is aware of the issuance of

the summons prior to compliance,[fn10] and he may challenge the

validity of the summons by attempting to

Page 301

intervene in the ensuing enforcement proceedings.[fn11]

[26] As for the grounds upon which the person summoned or the

intervenor may attack the summons in the enforcement proceeding,

Reisman held that one proper defense is "that the material is

sought for the improper purpose of obtaining evidence for use in

a criminal prosecution." 375 U.S. at 449, 84 S.Ct. at 513. This

statement was construed in Donaldson to mean that judicial

enforcement of a summons may be denied only where the sole

object of the investigation is to gather data for a criminal

prosecution, id. 400 U.S. at 553, 91 S.Ct. 534, and that a

summons would thus be enforced if issued in "good faith" and

"prior to a recommendation for criminal prosecution." Id. at

536, 91 S.Ct. at 545.

[27] Most recently, in United States v. LaSalle National Bank, ___

U.S. ___, 98 S.Ct. 2357, 57 L.Ed.2d 221 (1978), the Supreme Court

explained the Donaldson test as follows:

In summary, then, several requirements emerge for

the enforcement of an internal revenue summons.

First, the summons must be issued before the Service

recommends to the Department of Justice that a

criminal prosecution, which reasonably would relate

to the subject matter of the summons, be undertaken.

Second, the Service at all times must use the summons

authority in good-faith pursuit of the

congressionally authorized purposes of § 7602. This

second prerequisite requires the Service to meet the

Powell standards of good faith.[fn12] It also

requires that the Service not abandon in an

institutional sense . . . the pursuit of civil tax

determination or collection.

[28] Id. at ___, 98 S.Ct. at 2368, (footnote omitted). Thus,

according to LaSalle, the IRS may not in good faith, by means

of § 7602 summonses, gather evidence solely for a criminal

investigation.[fn13] Whether an investigation has solely criminal

purposes is to be determined not merely by reference to the

intent of the agent issuing the summons, but by "an examination

of the institutional posture of the IRS." Id.[fn14]

Page 302

[29] In United States v. McCarthy, 514 F.2d 368 (3d Cir. 1975),

this court carefully formulated procedural guidelines for use in

enforcement proceedings and provided that an evidentiary hearing

is an "integral part" of those proceedings. Under McCarthy, the

IRS must be prepared to make a preliminary showing that the

investigation has a legitimate purpose and that the inquiry may

be relevant to that purpose, that the information sought is not

already in the government's possession, and that the government

has followed the procedural steps required by the Internal

Revenue Code. The burden then shifts to the opposing party to

establish any defenses or to prove that enforcement would

constitute an abuse of the court's process.[fn15] If the district

court concludes that it cannot fairly decide the case on the

record before it, it may direct further proceedings, including

discovery, if requested. Id. at 372-73. See United States v.

Cortese, 540 F.2d 640 (3d Cir. 1976); United States v. First

National State Bank of New Jersey, 540 F.2d 619 (3d Cir. 1976),

cert. denied, 431 U.S. 954, 97 S.Ct. 2674, 53 L.Ed.2d 270

(1977); United States v. Lafko, 520 F.2d 622 (3d Cir.

1975).[fn16] Other courts have established similar procedures.

See United States v. Wright Motor Company, 536 F.2d 1090 (5th

Cir. 1976); United States v. Zack, 521 F.2d 1366 (9th Cir.

1975); United States v. Church of Scientology, 520 F.2d 818

(9th Cir. 1975); United States v. Turner, 480 F.2d 272 (7th

Cir. 1973); United States v. Salter, 432 F.2d 697 (1st Cir.

1970).

[30] In the instant case, however, none of the third parties upon

whom summonses were served contested their validity in court.

Because the third parties voluntarily complied with the

summonses, no enforcement proceedings were ever instituted by the

IRS. Moreover, since appellants, at least in most instances,

apparently had no knowledge that summonses had been issued until

after the third parties had complied,[fn17] they were unable to

stay compliance and thereby necessitate the institution of

enforcement proceedings in which they might have intervened.

[31] Nevertheless, appellants rely upon Donaldson v. United States

and United States v. Friedman for the proposition that even

where the third party voluntarily complies with a § 7602 summons,

the taxpayer's right to challenge the validity of the summons is

preserved at the trial level. In Donaldson, the IRS issued §

7602 summonses to Donaldson's former employers for the production

of the employers' business records relating to Donaldson's

employment. Donaldson obtained a court order staying compliance

by the third parties. The IRS sought judicial enforcement of the

summonses, and Donaldson moved to intervene, alleging in part

that the IRS investigation was criminal in nature. The Court

upheld the district court's denial of Donaldson's motion to

intervene on the grounds that intervention was a permissive, not

a mandatory right, and that Donaldson's interest, when balanced

against the need to facilitate

Page 303

IRS investigations, was of insufficient magnitude to warrant

intervention: "Donaldson's only interest — and of course it looms

large in his eyes — lies in the fact that those records

presumably contain details of Acme-to-Donaldson payments

possessing significance for federal income tax purposes. This

asserted interest, however, is nothing more than a desire by

Donaldson to counter and overcome Mercurio's and Acme's

willingness, under summons, to comply and to produce records. The

nature of the `interest' urged by the taxpayer is apparent from

the fact that the material in question (once we assume its

relevance) would not be subject to suppression if the government

obtained it by other routine means, such as by Acme's independent

and voluntary disclosure prior to summons, or by way of

identifiable deduction in Acme's own income tax returns, or

through Mercurio's appearance as a trial witness, or by subpoena

of the records for trial. This interest cannot be the kind

contemplated by [Federal Rule of Civil Procedure] Rule 24(a)(2)

when it speaks in general terms of `an interest relating to the

property or transaction which is the subject of the action.' What

is obviously meant there is a significantly protectable

interest." 400 U.S. at 531, 91 S.Ct. at 542. However, the Court

continued: "And the taxpayer, to the extent that he has such a

protectable interest, as, for example, by way of privilege, or

to the extent he may claim abuse of process, may always assert

that interest or that claim in due course at its proper place in

any subsequent trial. Cf. United States v. Blue,

384 U.S. 251, 86 S.Ct. 1416, 16 L.Ed.2d 510 (1966)." Id. at

531, 91 S.Ct. at 542 (emphasis added). Thus, the Donaldson

Court, in its effort to facilitate the investigatory mandate of

the IRS, merely postponed until trial the time at which a

taxpayer can demand adjudication of the propriety of a third

party summons.[fn18]

[32] In Friedman, the IRS brought an enforcement action to compel

compliance with summonses issued to third parties in connection

with an investigation into taxpayers' liability. The taxpayers

were permitted to intervene, and they attempted to resist

enforcement on the ground that the summonses sought evidence for

a criminal prosecution. The district court ordered the summonses

enforced and the taxpayers appealed. The taxpayers were unable to

obtain a stay of the enforcement orders pending appeal and the

third parties complied with the summonses. Because of this

compliance, the IRS moved to dismiss as moot the appeal from the

enforcement orders. In refusing to dismiss the appeal, this court

stated: "Although Friedman has complied with the court's order,

the legality of that order is still being challenged by the

taxpayer intervenors. If the taxpayers were to prevail in their

contention that all summonses were illegal because they were

issued

Page 304

solely to gather evidence for use in a criminal prosecution,

then the records acquired from Friedman would have been obtained

unlawfully. Such a ruling could affect the possible use of these

records in any subsequent criminal or civil proceeding brought

against the taxpayers. . . . We conclude that the motion to

dismiss the appeal . . . should be denied because the controversy

over these records is still very much alive." 532 F.2d at 931

(emphasis added).

[33] Although the trial judge in the instant case conceded that

appellants' claims may have been viable prior to the Supreme

Court's decision in United States v. Miller, 425 U.S. 435, 96

S.Ct. 1619, 48 L.Ed.2d 71 (1976), he held that Miller deprived

appellants of any standing which they might claim under

Donaldson and Friedman to assert at trial that administrative

summonses directed to third parties who voluntarily complied were

legally defective. In Miller, respondent made a pretrial motion

to suppress copies of bank records relating to his accounts at

two banks, both of which maintained the records pursuant to the

Bank Secrecy Act of 1970 (Act), on the grounds that the grand

jury subpoenas duces tecum used to obtain the records were

defective[fn19] and that the records had thus been seized in

violation of the Fourth Amendment. The district court denied the

motion to suppress, but the court of appeals reversed, holding

that a depositor's Fourth Amendment rights were violated when

bank records maintained under the Act are obtained by means of a

defective subpoena and that evidence so obtained must be

suppressed. The Supreme Court reversed on the ground that the Act

created no Fourth Amendment rights in the depositor and that

therefore respondent possessed no Fourth Amendment interest that

could be vindicated by a challenge to the subpoenas.[fn20] The

Court stated: "Since no Fourth Amendment interests of the

depositor are implicated here, this case is governed by the

general rule that the issuance of a subpoena to a third party to

obtain the records of that party does not violate the rights of a

defendant, even if a criminal prosecution is contemplated at the

time the subpoena is issued. California Bankers Assn. v.

Shultz, 416 U.S. 21 at 53, 94 S.Ct. 1494, 39 L.Ed.2d 812;

Donaldson v. United States, 400 U.S. 517, 537, 91 S.Ct. 534, 27

L.Ed.2d 580 (1971) (Douglas, J., concurring). Under these

principles, it was firmly settled, before the passage of the Bank

Secrecy Act, that an Internal Revenue Service summons directed to

a third-party bank does not violate the Fourth Amendment rights

of a depositor under investigation. See First National Bank v.

United States, 267 U.S. 576, 45 S.Ct. 231, 69 L.Ed. 796 (1925),

aff'g 295 F. 142 (S.D.Ala. 1924). See also, California Bankers

Assn. v. Shultz, supra, 416 U.S. at 53, 94 S.Ct. 1494;

Donaldson v. United States, 400 U.S., at 522, 91 S.Ct. 534."

425 U.S. at 444, 96 S.Ct. at 1624. In holding that respondent

lacked "the requisite Fourth Amendment interest" to contest the

validity of the subpoenas, the Court noted that there was "no

occasion for us to address whether the subpoenas complied with

the requirements outlined in Walling. The banks upon which they

were served did not contest their validity." Id. at 446 n.9, 96

S.Ct. at 1626.[fn21]

[34] The trial judge in the instant case characterized Miller as a

"standing" case and

Page 305

ruled that just as Miller, in the absence of a constitutionally

based interest, lacked standing to press his challenge to the

validity of the subpoenas, so defendants herein "simply lack

standing . . to assert a claim that an administrative summons

directed at a third party (who thereafter complied voluntarily)

was defective." According to the trial judge, any assertion of

standing based upon Donaldson and Friedman was "washed away"

in the wake of Miller. In so holding, the trial judge relied

upon the recent decision of United States v. Sand,

541 F.2d 1370 (9th Cir. 1976), in which the Court of Appeals

for the Ninth Circuit stated: "Both defendants sought to exclude

Sand's bank records which the government obtained from several

banks by using civil tax summonses. The crux of their objections

was that the IRS investigation was from its inception criminal

and that the use of IRC § 7602 summonses in aid of a solely

criminal investigation was improper, citing Donaldson v. United

States, 1971, 400 U.S. 517, 531-36, 91 S.Ct. 534, 27 L.Ed.2d

580. However, the Court held in United States v. Miller,

425 U.S. 435, 96 S.Ct. 1619, 48 L.Ed.2d 71 (1976), that a

depositor has no standing to challenge an IRS summons directed at

his bank. Id. at [444], 96 S.Ct. 1619. Hence, the district court

was correct in denying the motion to suppress." 541 F.2d at 1374

(emphasis added). Cf. United States v. Herndon,

536 F.2d 1027 (5th Cir. 1976).

[35] We decide, however, that Miller does not deprive the

appellants of standing in this case and that Sand erroneously

misconstrued the breadth of Miller's holding. The Miller

court was not faced with the question of whether or not a

taxpayer has standing to contest the legality of a § 7602

summons. Rather, Miller dealt only with a Fourth Amendment

challenge to an allegedly improper grand jury subpoena. It

appears that Miller's claim of defectiveness was intertwined with

his Fourth Amendment argument,[fn22] and the Court appropriately

framed its holding in constitutional terms.[fn23] Because "Fourth

Amendment rights are personal rights which . . . may not be

vicariously asserted," Alderman v. United States, 394 U.S. 165,

174, 89 S.Ct. 961, 966, 22 L.Ed.2d 176 (1969), the Court did not

have to reach the question of the validity of the subpoenas since

only the banks, under a traditional Fourth Amendment analysis,

had standing to raise it.[fn24]

[36] In the instant case, however, appellants' standing to challenge

administrative summonses derives not from the Fourth

Amendment,[fn25] but rather from a federal statute, § 7602, and

from the gloss placed upon that statute by the federal courts. We

think that in consistently holding that the IRS may not use

administrative summonses

Page 306

to gather evidence in an exclusively criminal investigation, the

courts from Reisman and Donaldson onward, up to and including

LaSalle, have identified a protectable interest in the taxpayer

not to be the target of an exclusively criminal investigation in

which government agents have acted beyond their statutory

authority. If the civil limitation placed upon § 7602 summonses

is not for the taxpayer's benefit, we have difficulty in

discerning the party for whose protection it was designed. While

the third party recipients of summonses may well be motivated to

refuse to comply on the grounds that the summonses are overbroad

or unreasonably burdensome, see e.g., United States v. Friedman,

supra, at 931, 933-34; United States v. Dauphin Deposit Trust

Co., 385 F.2d 129 (3d Cir. 1967), cert. denied,

390 U.S. 921, 88 S.Ct. 854, 19 L.Ed.2d 981 (1968), there is

little reason to expect them to raise the defense that the

summonses were issued to further a solely criminal investigation

of the taxpayer. Cf. United States v. Continental Bank & Trust

Co., 503 F.2d 45 (10th Cir. 1974). This is not a matter of

the third party bank's interest, but of the taxpayer's. Thus, the

courts have provided that the taxpayer may challenge the validity

of a summons issued to a third party either at the investigatory

stage or, if necessary, at the trial level. Reisman v. Caplin;

Donaldson v. United States; United States v. LaSalle National

Bank; United States v. Friedman; United States v. Lafko; United

States v. McCarthy, supra.

[37] As has frequently been noted, the rationale of these cases

derives from the distinct roles traditionally accorded the

investigatory functions of the grand jury, on the one hand, and

the IRS, on the other hand. Grand jury subpoenas, such as those

involved in Miller, are used to garner evidence to be presented

to a federal grand jury, whose sole purpose is to investigate

criminal activity. It is exclusively a criminal investigatory

tool. But an IRS administrative summons is a process essentially

civil in character. While a summons may result in obtaining

evidence which might ultimately find its way to a grand jury, the

statutory authority for its issuance is civil and the evidentiary

objective at the time of its issuance must be civil in nature.

Thus, the grand jury apparatus has traditionally been the means

by which evidence required to form the basis of a contemplated

criminal charge can be compulsorily produced, and the courts, in

construing § 7602, have identified a protectable interest,

assertable by the taxpayer, in preventing the IRS from

encroaching upon what has traditionally been the sole province of

the grand jury.[fn26]

Page 307

[38] Were Miller to be held dispositive of the present case,

serious doubt would be cast upon those decisions, including

Donaldson and LaSalle, which hold that IRS summonses are

improper if used in furtherance of an IRS investigation conducted

solely for criminal purposes, since, as stated above, that

limitation makes little sense if the taxpayer — the only party

properly motivated to challenge the summons on the ground of

illegality — is not permitted to do so. Miller, however, by its

very terms suggests that it was not intended to disturb the

vitality of Donaldson. The Miller Court referred to

Donaldson only for the proposition that "an IRS summons

directed to a third party bank does not violate the Fourth

Amendment rights of a depositor under investigation." 425 U.S.

at 444, 96 S.Ct. at 1624 (emphasis added). Even at the time

Donaldson was decided, as the Miller Court notes, it was well

established that the issuance of a summons to a third party does

not violate the taxpayer's Fourth Amendment rights. See

Donaldson, 400 U.S. at 522, 91 S.Ct. 534. Donaldson itself was

a case involving no Fourth Amendment claims whatsoever. Id.

Thus the Miller Court compared its ruling to Donaldson only

in the sense that neither § 7602 summonses nor grand jury

subpoenas issued to third parties are vulnerable to Fourth

Amendment challenges by taxpayers. But Miller did not purport

to cast doubt on Donaldson's conclusion that even where there

is no Fourth Amendment challenge to a summons involved, "the

taxpayer . . . to the extent he may claim abuse of process, may

always assert . . . that claim in due course at its proper place

in any subsequent trial."

[39] Having concluded that Miller does not bar appellants'

standing to assert at trial the illegality of § 7602 summons, we

must next examine appellants' contentions that if, on remand, a

hearing is granted and abuse of the summons process is found, the

proper remedy is the suppression of any evidence and the fruits

thereof obtained by virtue of the illegal summonses. The trial

judge ruled, and the government contends on appeal, that the

drastic remedy of suppression, controversial enough where

constitutional violations are urged, is improper where the

violations complained of are merely statutory in character. We

think, however, that Donaldson and Friedman, cited by

appellants, clearly envision such a remedy. In Friedman, this

court stated that proof that a § 7602 summons had been invalidly

issued "could affect the possible use [of the summoned records]

in any subsequent criminal or civil proceeding brought against

the taxpayers." 532 F.2d at 936. Moreover, Donaldson cited

United States v. Blue, 384 U.S. 251, 86 S.Ct. 1416, 16 L.Ed.2d

510 (1966), as support for the proposition that the taxpayer

could always assert a claim of abuse of process in any subsequent

trial. 400 U.S. at 517, 91 S.Ct. 534. In Blue, the Court

stated: "Even if we assume that the Government did acquire

incriminating evidence in violation of the Fifth Amendment, Blue

would at most be entitled to suppress the evidence and its fruits

if they were sought to be used against him at trial. While the

general common-law practice is to admit evidence despite its

illegal origins, this Court in a number of areas has recognized

or developed exclusionary rules where evidence has been gained in

violation of the accused's rights under the Constitution,

federal statutes, or federal rules of procedure." 384 U.S. at

255, 86 S.Ct. at 1419 (citations omitted) (emphasis added).[fn27]

Page 308

[40] Other courts, as well, have found suppression to be a

theoretically proper remedy to cure governmental violations of

the Internal Revenue Code. In United States v. Oaks, 360

F. Supp. 855 (C.D.Cal. 1973), defendant taxpayer moved to suppress

information acquired pursuant to § 7602 summonses on the ground

that the summonses were employed for the improper purpose of

furthering a solely criminal investigation. The court, without

questioning the propriety of the remedy of suppression, denied

the taxpayer's motion only because it found on the facts before

it that the summonses complied with the Donaldson standards.

See United States v. Fruchtman, 421 F.2d 1019 (6th Cir.),

cert. denied, 400 U.S. 849, 91 S.Ct. 39, 27 L.Ed.2d 86 (1970).

In Application of Leonardo, 208 F. Supp. 124 (N.D.Cal. 1962),

which involved a claim by taxpayers that the IRS had violated

26 U.S.C. § 7605(b), the court, in ordering suppression, held that

"apart from the claim of violation of constitutional rights, it

is our view that this court can and should grant relief through

an adequate and appropriate remedy to safeguard these petitioners

from what we deem to be an abuse of the statutory process." Id.

at 126-27.[fn28] A similar view was espoused by the court in

United States v. Avila, 227 F. Supp. 3 (N.D.Cal. 1963), which

stressed that "[a]lthough the so-called `fruit of the poisonous

tree' doctrine has generally been applied in cases involving

searches in violation of the Fourth Amendment . . ., the doctrine

can be applied to searches in violation of a statutory right."

Id. at 6, citing Nardone v. United States, 308 U.S. 338, 60

S.Ct. 266, 84 L.Ed. 307 (1939). In an analogous context, the

court in Moloney v. United States, 375 F. Supp. 737 (N.D.Ohio

1974), stated: "The Government also argues that [26 U.S.C. § 3631]

does not contain any sanctions for such a violation as

occurred here. The Court is not inclined to render the section

nugatory because it does not state explicitly that no assessment

of deficiency can be made on the basis of an inspection forbidden

by the section. Such a result is implicit in the statute.

Otherwise it would be completely meaningless." Id. at 741.

[41] To make available the remedy of suppression to taxpayers in

cases such as the present is merely to ensure governmental

compliance with the principles enunciated in Reisman, Donaldson,

LaSalle, and the decisions of this circuit: the IRS, in issuing

administrative summonses under § 7602, may not act outside its

statutory authority by garnering evidence in furtherance of a

solely criminal investigation. If a court determines in the

context of enforcement proceedings that a summons was illegally

issued, it will deny enforcement of the summons. 400 U.S. at 533,

91 S.Ct. 534. That summons is no less illegal merely because it

escapes detection at the investigatory stage. The prophylactic

principles which operate at the enforcement level are equally

appropriate to the trial stage, and suppression is the only

practical remedy at that point to cure the statutory abuse.[fn29]

Page 309

[42] In an analogous situation, the Supreme Court stressed that the

preliminary stages of criminal prosecutions must be pursued in

strict obedience to both the Constitution and the laws of the

United States. In Abel v. United States, 362 U.S. 217, 80 S.Ct.

683, 4 L.Ed.2d 668 (1960), the Court was called upon by the

defendant to adjudicate the claim that the government had used an

administrative warrant, which could be used only to detain a

person who was to be deported, for an entirely illegitimate

purpose. The defendant asserted that the purpose was to place him

in custody so that pressure might be brought to bear on him and

to permit the government to search through his belongings for

evidence of alleged espionage. The defendant argued that the

articles seized as a consequence of the use of this illegal

administrative warrant should have been suppressed. The Court

stated: "Were this claim justified by the record, it would indeed

reveal a serious misconduct by law-enforcing officers. The

deliberate use by the government of an administrative warrant for

the purpose of gathering evidence in a criminal case must meet

stern resistance by the courts. The preliminary stages of a

criminal prosecution must be pursued in strict obedience to the

safeguards and restrictions of the Constitution and laws of the

United States." 362 U.S. at 226, 80 S.Ct. at 690. The Court

stressed that the issues were fully explored by the court below

and crucial facts were found against defendant. Accordingly, it

was precluded from making a finding of bad faith on that record.

However, the Court again noted: "We emphasize again that our view

of the matter would be totally different had the evidence

established, or were the courts below not justified in not

finding, that the administrative warrant was here employed as an

instrument of criminal law enforcement to circumvent the latter's

legal restrictions, rather than as a bona fide preliminary step

in a deportation proceeding." Id. at 230, 80 S.Ct. at 692.

[43] In sum, although § 7602 does not expressly restrict the power

to issue a summons thereunder as long as the purpose is to

ascertain the correctness of any return and the material sought

is relevant to such inquiry, LaSalle, Donaldson, Friedman, and

the other cited decisions have promulgated a judicial policy,

binding on the IRS, to protect a taxpayer from any attempt on the

part of the IRS to obtain evidence by use of § 7602 summonses

after the IRS recommends prosecution to the Department of Justice

or after the IRS has abandoned, in an institutional sense, the

pursuit of civil tax determination or collection. The only

effective remedy for violation of that policy is to require

suppression of the evidence obtained as the evidentiary fruits of

an illegal summons.

[44] The government, however, contends that even if the remedy of

suppression is theoretically available to taxpayers, it is an

inappropriate remedy under the circumstances of this particular

case. First, the government implies that appellants have "waived"

any opportunity to seek suppression of evidence at trial because

they knew of the issuance of at least some of the summonses prior

to the third parties' compliance and failed to request the court

to stay such compliance or to seek other judicial relief at that

earlier stage. In United States v. House, supra, this court,

considering a claim that evidence obtained in alleged violation

of 26 U.S.C. § 7605(b) should be suppressed, stated: "Moreover,

if the taxpayers had felt aggrieved by the proposed visits to

Spuler's office or their own, they could have resisted them and

forced

Page 310

the Internal Revenue Service to resort to a subpoena. If they

had, they would have obtained judicial review of both the

necessity for a notice and the propriety of a second examination.

We can hardly countenance as a ground for suppression an

examination to which the taxpayer, having available alternatives,

consented." 524 F.2d at 1043-44.

[45] The record in the present case is unclear as to the precise

extent of appellants' knowledge of the issuance of the

summons.[fn30] However, assuming arguendo that appellants were

aware, prior to compliance, that summonses had been issued to

third parties, and that they failed, intentionally or otherwise,

to institute judicial proceedings at that point in time, we do

not think this would necessarily bar them from asserting a claim

of abuse, of process at trial. Donaldson indicated that the

taxpayer can attack the validity of the summons at trial even

though he has sought and been denied intervention, and it nowhere

suggests that the taxpayer must exhaust his pre-indictment

remedies before proceeding at the trial level. See Garrett v.

United States, 511 F.2d 1037 (9th Cir. 1975); United States v.

Newman, 441 F.2d 165 (5th Cir. 1971). We note, in addition, that

the Senate Report accompanying 26 U.S.C. § 7609, added by the Tax

Reform Act of 1976, which gives taxpayers the statutory right to

stay voluntary compliance and intervene in enforcement

proceedings, states that where the taxpayer "does not request

the third party witness not to comply at this stage, he would

still be permitted to assert such defenses as may be available

to him with respect to any evidence obtained pursuant to the

summons in any later court action in which the [taxpayer] was

directly involved (i. e., affecting his tax liability or any

criminal charges which might be brought) to the same extent as

may be permitted under present law." Senate Report No. 94-938,

94th Cong., 2d Sess. 370 (1976) (emphasis added).[fn31]

[46] Finally, the government asserts that as a practical matter

suppression would gain the appellants nothing in the case.

According to the government, grand jury subpoenas were issued to

many, if not all, of the same parties who received administrative

summonses. The only "taint" which the appellants can claim, urges

the government, is that the "identities" of the subpoenaed third

parties were learned by way of the summonses and that the

subpoenas were therefore fatally infected. The government

stresses that this claim is without merit because the fact that

the summonses themselves were served on the third parties

demonstrates that their identities were already known prior to

the issuance of the summonses. However, the present record

contains no complete accounting of the dates of

Page 311

the subpoenas or the summonses or of the parties on whom they

were served. While the government may well be able to establish

an independent, "taint-free" basis for its evidence, see Wong

Sun v. United States, 371 U.S. 471, 83 S.Ct. 407, 9 L.Ed.2d

441 (1963), we are unable to so conclude on the record before us

"Statements made by counsel in their briefs are not evidence."

United States v. Howard, 360 F.2d 373 (3d Cir. 1966).

[47] We thus conclude that the trial judge erred in ruling that as a

matter of law appellants lacked standing to attack the validity

of the summonses and to suppress the illegally obtained

evidentiary fruits thereof. Accordingly, in light of the

allegations of governmental impropriety raised by appellants, we

shall remand this case to the district court with instructions to

conduct an evidentiary hearing[fn32] and to certify to this court

its findings of fact and conclusions of law as to whether the

government fully complied with the requirements of 26 U.S.C. § 7602,

as judicially interpreted, and if not, whether suppression

is required. We note that the trial judge did not have the

benefit of the Supreme Court's opinion in United States v.

LaSalle National Bank at the time he rendered his decision, and

the present record is insufficient to permit as to determine

conclusively whether or not the IRS summonses were issued in good

faith and prior to a recommendation for prosecution, as those

standards are defined in LaSalle. Although the government has

submitted evidence which allegedly obviates the need for an

evidentiary hearing, this evidence apparently was not presented

to the district court in the first instance and therefore cannot

be considered by this court on appeal. See Stotter & Co., Inc.

v. Amstar Corp., 579 F.2d 13 (3d Cir. 1978) and the authorities

cited in n.4 of Rose Marie Drexel v. Union Prescription Centers,

Inc., 582 F.2d 781 (3d Cir. 1978).

[48] The case will be remanded for prompt proceedings consistent

with this opinion. We retain jurisdiction over this appeal.[fn33]

Footnotes

[fn1] Although appellants do not contest the sufficiency of the

evidence relating to their convictions on the corporate tax

evasion counts, they do suggest, but only in their statement of

facts, that the government offered no proof that the Corporation

had deducted on its books and records expenses for which it later

received reimbursement. In fact, the only deductions taken by the

Corporation for repair of marine damage during the relevant

period was the salary of two body shop employees, totaling

$22,500 per year. The government, however, argues that it was

trying not a net worth method of proof case, but rather a

specific items method of proof case, under which it is sufficient

to show that contrary to usual practices a defendant received

certain payments in cash which were not in turn reported on

income tax returns. See, e. g., United States v. Bray, 546 F.2d 851

(10th Cir. 1976); United States v. Stein, 437 F.2d 775 (7th

Cir.), cert. denied, 403 U.S. 905, 91 S.Ct. 2205, 29 L.Ed.2d

680 (1971).

[fn2] The government introduced Exhibit G-59, which attributed in

summary fashion the various bonds purchased with funds from the

Hackensack Account to either Genser or Forman, or to both. The

exhibit was based upon bank statements reflecting withdrawals

from the Hackensack Account, bond purchase documentations

obtained from the various brokerage houses, coupon collection

letters of the First National State Bank in Millburn which

recorded bond coupon negotiations by the appellants (Exhibit

G-26), and the testimony of witnesses who had received bonds or

coupons from the appellants.

[fn3] The government, however, contends that the liquidation

itself was improper because none of the bonds were reflected on

the closing tax returns in 1973.

[fn4] It is unclear whether appellants are suggesting that, in

general, IRS conduct in this case is not to be trusted, or that

the allegedly illegal summonses were used to obtain documents

upon which the audit was based.

[fn5] Although no evidentiary hearing was ever held, appellants

contended in the district court, and allege on appeal, that in

1971 the IRS began an audit of the books and records of the

corporation for the taxable years 1969 and 1970. The audit

resulted in a finding of no deficiency for both years. On

November 14, 1974, the IRS began a second investigation, pursuant

to 26 U.S.C. § 7605(b), into taxable years 1969 and 1970 as well

as into taxable years 1971-1974. Throughout the second

investigation, in 1974 and 1975, Special Agents of the IRS served

administrative summonses, issued under the authority of 26 U.S.C. § 7602,

to the following persons and corporations: (1) several

summonses were served on the corporation's accountant between

August 1974 and January 1975 to produce the corporation's work

papers; (2) the First National State Bank of New Jersey received

at least eight summonses between November 1974 and January 1975,

as well as one summons not bearing a date; (3) summonses of

unknown number and date were served on the City National Bank in

Hackensack; (4) a summons was issued to one Stan Kramer on

October 30, 1975, to testify on November 18, 1975. Appellants

allege that additional summonses were issued to other persons and

entities, but stress that there is no record to establish the

identities of the parties and the dates of issuance.

[fn6] Section 7602 provides in pertinent part: "For the purpose

of ascertaining the correctness of any return, making a return

where none has been made, determining the liability of any person

for any internal revenue tax or the liability at law or in equity

of any transferee or fiduciary of any person in respect of any

internal revenue tax, or collecting any such liability, the

Secretary or his delegate is authorized — * * * (2) To summon the

person liable for tax or required to perform the act, or any

officer or employee of such person, or any person having

possession, custody, or care of books of account containing

entries relating to the business of the person liable for tax or

required to perform the act, or any other purpose the Secretary

or his delegate may deem proper, to appear before the Secretary

or his delegate at a time and place named in the summons and to

produce such books, papers, records, or other data, and to give

such testimony, under oath, as may be relevant or material to

such inquiry. . . ."

[fn7] Subsequent to pleading not guilty, appellants filed a

motion, argued before the district court on July 26, 1976, to

suppress all evidence gained by the government through the use of

any illegally issued summonses. Appellants also requested an

evidentiary hearing to determine conclusively the facts

surrounding the issuance of the summonses. The district court

denied the motion to suppress and refused to grant an evidentiary

hearing. The request for a hearing was renewed by letter dated

August 16, 1976. Following their convictions, appellants, on

January 5, 1977, again petitioned for a hearing. On February 4,

1977, the trial judge filed a letter opinion denying appellants'

request on the grounds, inter alia, that the district court no

longer had jurisdiction over the matter. United States v.

Ellenbogen, 390 F.2d 537, 542-43 (2d Cir. 1968), cert. denied,

393 U.S. 918, 89 S.Ct. 241, 21 L.Ed.2d 206 (1969), and that in

any event appellants lacked standing to attack the validity of

the summons.

[fn8] Section 7602 does not provide the IRS with the power to

enforce its own summonses. To compel compliance with a summons,

the IRS must bring an enforcement proceeding in a federal

district court. 26 U.S.C. §§ 7402(b), 7604(a). Such an

enforcement action is "an adversary proceeding affording a

judicial determination of the challenges to the summonses and

giving complete protection to the witness." Reisman v. Caplin,

supra, 375 U.S. at 446, 84 S.Ct. at 512.

[fn9] This procedure was suggested by the Reisman court, which

held that "third parties might intervene [in enforcement

proceedings] to protect their interests, or in the event the

taxpayer is not a party to the summons before the hearing

officer, he too may intervene. . . . Nor would there be a

difference should the witness indicate . . . that he would

voluntarily turn the papers over to the Commissioner. If this be

true, either the taxpayer or any affected party might restrain

compliance . . . until compliance is ordered by a court of

competent jurisdiction." 375 U.S. at 449-50, 84 S.Ct. at 514

(citations omitted); see Donaldson v. United States, supra, 400

U.S. at 519-20, 91 S.Ct. 534; Callahan v. First Pennsylvania

Bank, 422 F. Supp. 1098 (E.D.Pa. 1976).

[fn10] Prior to the recent enactment of 26 U.S.C. § 7609 (see

note 11 infra), the IRS was not required to give notice to the

taxpayer under investigation that a summons had been served on a

third party. United States v. Continental Bank & Trust Co.,

503 F.2d 45 (10th Cir. 1974); Application of Cole, 342 F.2d 5 (2d

Cir. 1965).

[fn11] The taxpayer's right to intervene in enforcement

proceedings is permissive only and not mandatory. Donaldson v.

United States, supra, 400 U.S. at 529-31, 91 S.Ct. 534. However,

under 26 U.S.C. § 7609, added by the Tax Reform Act of 1976

(Pub.L. 94-455, 90 Stat. 1699-1702), taxpayers must be notified

by the IRS that a summons has been issued to a third party and

they are entitled as of right to stay voluntary compliance and to

intervene in enforcement proceedings. Section 7609 applies only

to summonses issued after February 28, 1977, and is thus

inapplicable to the instant case. Pub.L. 94-455, § 1205(c), as

amended by Pub.L. 94-528, § 2(b), 90 Stat. 2483.

[fn12] In United States v. Powell, 379 U.S. 48, 85 S.Ct. 248,

13 L.Ed.2d 112 (1964), the Court stated that the IRS "must show

that the investigation will be conducted pursuant to a legitimate

purpose, that the inquiry may be relevant to the purpose, that

the information sought is not already within the Commissioner's

possession, and that the administrative steps required by the

Code have been followed." Id. at 57-58, 85 S.Ct. at 255.

[fn13] Although it emphasized the interrelated criminal and civil

nature of IRS investigations, the Court stated: "The Service does

not enjoy inherent authority to summon production of the private

papers of citizens. It may exercise only that authority granted

by Congress. In § 7602 Congress has bestowed upon the Service the

authority to summon production for four purposes only: for

`ascertaining the correctness of any return, making a return

where none has been made, determining the liability of any person

for any internal revenue tax . . or collecting any such

liability.' Congress therefore intended the summons authority to

be used to aid the determination and collection of taxes. These

purposes do not include the goal of filing criminal charges

against citizens. Consequently, summons authority does not exist

to aid criminal investigations solely. . . We . . . could uncover

nothing in the Code or its legislative history to suggest that

Congress intended to permit exclusively criminal use of

summonses. As a result, the IRS employs its authority in good

faith when it pursues the four purposes of § 7602 which do not

include aiding criminal investigations solely." ___ U.S. at ___

n. 18, 98 S.Ct. at 2367.

[fn14] Determining that "[n]othing in § 7602 or its legislative

history suggests that Congress intended the summons authority to

broaden the Justice Department's right of criminal litigation

discovery or to infringe on the role of the grand jury as a

principal tool of criminal accusation," id. at ___, 98 S.Ct. at

2365, the Court stressed that the IRS would not be proceeding in

good faith if it delayed in submitting a recommendation to the

Justice Department when there was an institutional commitment to

make the referral and the IRS merely desired to gather additional

evidence for the prosecution, or if the IRS became "an

information gathering agency for other departments including the

Department of Justice, regardless of the status of criminal

cases." Id. at ___, 98 S.Ct. at 2367.

[fn15] The burden is on the taxpayer to negate the existence of a

proper civil purpose. United States v. Fisher, 500 F.2d 683 (3d

Cir. 1974), aff'd 425 U.S. 391, 96 S.Ct. 1569, 48 L.Ed.2d 39

(1976); United States v. Bowman, 435 F.2d 467 (3d Cir. 1970);

United States v. DeGrosa, 405 F.2d 926 (3d Cir.), cert.

denied, 394 U.S. 973, 89 S.Ct. 1465, 22 L.Ed.2d 753 (1969). The

Supreme Court has characterized this burden as "heavy." United

States v. LaSalle National Bank, supra, ___ U.S. at ___, 98

S.Ct. 2357.

[fn16] The McCarthy court stated: "Although our proposed

procedure for summons enforcement contemplates that provision for

an evidentiary hearing be an integral part of the proceedings,

implicit in our design is the realization that not every summons

enforcement proceeding will require an evidentiary hearing. Thus,

if the person summoned neither puts in issue allegations of the

complaint nor raises proper affirmative defenses, no evidentiary

hearing will be required; the matter can be decided on the

pleadings." 514 F.2d at 373.

[fn17] See note 30 and accompanying text infra.

[fn18] Several courts have perceived that the Donaldson Court's

recognition that the taxpayer can raise his claims of abuse of

process at trial was a significant factor in its decision to

limit his opportunity to raise those claims during the

investigatory stage. In Garrett v. United States, 511 F.2d 1037

(9th Cir. 1975), the district court denied the taxpayers

permission to intervene in an enforcement action brought by the

IRS to compel compliance with a summons served on the taxpayers'

bank. In affirming, the Court of Appeals for the Ninth Circuit

stated that the district court "was not required to allow

intervention, and the attendant discovery procedures necessary to

support the allegations, to delay the investigation into

taxpayers' tax liabilities, because, as the Court pointed out

in Donaldson, `the taxpayer, to the extent . . that he may

claim abuse of process, may always assert . . . that claim in due

course at its proper place in any subsequent trial.'" Id. at

1038 (emphasis added). Moreover, the court in United States v.

Newman, 441 F.2d 165 (5th Cir. 1971), in denying the taxpayer's

motion to intervene in enforcement proceedings, noted that in

United States v. Powell, 379 U.S. 48, 85 S.Ct. 248, 13 L.Ed.2d

112 (1964), the Court analogized an investigation by the IRS to

one conducted by a grand jury or the Federal Trade Commission in

that a person can be denied certain adjudicatory rights in light

of the government's need to investigate and inquire. But the

Newman court continued: "An important factor back of this

approach is of course the fact that if accusatory proceedings are

begun the person concerned `will be accorded all the traditional

judicial safeguards at a subsequent adjudicative proceeding

. . . .' And this applies in the context of an IRS summons

situation as Donaldson makes clear." Id. at 174 (citations

omitted).

[fn19] Respondent argued that the subpoenas were defective

because they were issued by a United States Attorney rather than

a court, no return was made to a court, and the subpoenas were

returnable on a date when the grand jury was not in session. 425

U.S. at 439, 96 S.Ct. 1619.

[fn20] The Court declined to consider the government's

contentions that the appeals court erred in holding that the

subpoenas were defective and that suppression was the appropriate

remedy if a constitutional violation did occur. 425 U.S. at 440,

96 S.Ct. 1619.

[fn21] In Oklahoma Press Publishing Company v. Walling,

327 U.S. 186, 66 S.Ct. 494, 90 L.Ed. 614 (1946), the Court stated

that "the Fourth [Amendment], if applicable [to subpoenas for the

production of business records and papers], at the most guards

against abuse only by way of too much indefiniteness or breadth

in the things required to be `particularly described,' if also

the inquiry is one the demanding agency is authorized by law to

make and the materials specified are relevant." Id. at 208, 66

S.Ct. at 505.

[fn22] As the Miller Court stated: "Respondent appears to

contend that a depositor's Fourth Amendment interest comes into

play only when a defective subpoena is used to obtain records

kept pursuant to the Act. We see no reason why the existence of a

Fourth Amendment interest turns on whether the subpoena is

defective. Therefore, we do not limit our consideration to the

situation in which there is an alleged defect in the subpoena

served on the bank." 425 U.S. at 441 n.2, 96 S.Ct. at 1623.

[fn23] Indeed, this court has described Miller as follows:

"Miller urged that he had a Fourth Amendment interest in the

records kept by the banks, as copies of personal records made

available to the banks for a limited purpose. However, the

Supreme Court, after considering the standards enunciated in

Katz v. United States, 389 U.S. 347, 88 S.Ct. 507, 19 L.Ed.2d

576 . . . and Couch v. United States, 409 U.S. 322, 93 S.Ct.

611, 34 L.Ed.2d 548 . . . found no legitimate expectation of

privacy in the contents of records maintained by the banks under

the mandate of the Act. . . ." Gannet v. First National State

Bank of New Jersey, 546 F.2d 1072 (3d Cir. 1976), cert.

denied, 431 U.S. 954, 97 S.Ct. 2674, 53 L.Ed.2d 270 (1977)

(emphasis added).

[fn24] In Alderman v. United States, supra, the Court stated

that the "established principle is that suppression of the

product of a Fourth Amendment violation can be successfully urged

only by those whose rights were violated by the search itself,

not by those who are aggrieved solely by the introduction of

damaging evidence." 394 U.S. at 171-72, 89 S.Ct. at 965. See

United States v. Miller, supra, 425 U.S. at 456, 96 S.Ct. 1619

(Marshall, J., dissenting).

[fn25] Appellants expressly deny any Fourth Amendment interest in

the summoned materials.

[fn26] In United States v. Friedman, this court, noting that

the IRS has no authority to conduct a criminal investigation

through the use of a § 7602 civil summons, explained as follows:

"No court has given a thorough or persuasive justification for

this construction of 26 U.S.C. § 7602 which appears to have

originated in an opinion by Judge Wyzanski in United States v.

O'Connor, 118 F. Supp. 248 (D.Mass. 1953), and to have been

assumed, rather than explained, ever since. Judge Wyzanski

reasoned: `The Constitution of the United States, the statutes,

the traditions of our law, the deep rooted preferences of our

people speak clearly. They recognize the primary and nearly

exclusive role of the Grand Jury as the agency of compulsory

disclosure. That is the inquisitorial body provided by our

fundamental law to subpoena documents required in advance of a

criminal trial, and in the preparation of an indictment or its

particularization. . . .' 118 F. Supp. at 250-51. The paragraph

has a nice ring, but it ignores the reality that grand jury

subpoenas are issued as a matter of course by the Department of

Justice, not by the grand jury. See In re Grand Jury

Proceedings, 486 F.2d 85 (3d Cir. 1973). It is hard to imagine

why Congress could not entrust criminal law enforcement of the

Internal Revenue Code to an executive branch department rather

than or in addition to the Justice Department. The difference

between a summons returnable before an IRS agent and a subpoena

returnable before a grand jury is in the real world slight.

"The critical question, however, is what Congress intended in §

7602 and its predecessors, as well as in 26 U.S.C. § 7801(a)

which authorizes the Secretary of the Treasury to administer and

enforce the provisions of the Internal Revenue Code. The

Intelligence Division of the IRS is organized to carry out the

broad enforcement responsibilities of the Treasury Secretary

under § 7801(a). Since Judge Wyzanski's opinion in 1953, no case

which has addressed the issue of the scope of a § 7602 summons

has explored the legislative intention in any depth. Nor do we,

since the United States v. O'Connor construction has been

accepted by the Supreme Court. See, e. g., Donaldson v. United

States, supra, 400 U.S. at 533, 91 S.Ct. 534." 532 F.2d at 932

n.9.

In United States v. LaSalle National Bank, supra, the Court

emphasized that "[n]othing in § 7602 or its legislative history

suggests that Congress intended the summons authority to broaden

the Justice Department's right of criminal litigation discovery

or to infringe on the role of the grand jury as a principal tool

of criminal accusation." ___ U.S. at ___, 98 S.Ct. at 2365.

[fn27] In one of the cases cited by Blue for this proposition,

Nardone v. United States, 308 U.S. 338, 60 S.Ct. 266, 84 L.Ed.

307 (1939), evidence procured by wiretapping in violation of the

Communications Act of 1934 was held inadmissible at trial. The

Nardone Court stated: "Any claim for the exclusion of evidence

logically relevant in criminal prosecutions is heavily

handicapped. It must be justified by an overriding public policy

expressed in the Constitution or the law of the land. . . . [T]wo

opposing concerns must be harmonized: on the one hand, the stern

enforcement of the criminal law; on the other, protection of that

realm of privacy left free by Constitution and laws but capable

of infringement either through zeal or design. In accommodating

both these concerns, meaning must be given to what Congress has

written, even if not in explicit language, so as to effectuate

the policy which Congress has formulated." Id. at 340, 60 S.Ct.

at 267.

[fn28] In United States v. House, 524 F.2d 1035 (3d Cir. 1975),

this court declined to decide whether a violation by the

government of § 7605(b) is a ground for a suppression motion in a

criminal case because it found on the record that no § 7605(b)

violation had occurred. Id. at 1043; see United States v.

Dawson, 400 F.2d 194 (2d Cir. 1968), cert. denied, 393 U.S. 1023,

89 S.Ct. 632, 21 L.Ed.2d 567 (1969).

[fn29] On several occasions the Supreme Court has stressed that a

primary justification for the exclusionary rule, at least in the

context of the Fourth Amendment, is the deterrence of illegal

government conduct. See, e. g., Stone v. Powell, 428 U.S. 465,

96 S.Ct. 3037, 49 L.Ed.2d 1067 (1976); United States v.

Calandra, 414 U.S. 338, 94 S.Ct. 613, 38 L.Ed.2d 561 (1974);

Elkins v. United States, 364 U.S. 206, 80 S.Ct. 1437, 4 L.Ed.2d

1669 (1960). Suppression in cases such as the present furthers

this policy even though 26 U.S.C. § 7609, added by the Tax Reform

Act of 1976, now statutorily provides an opportunity for targets

of IRS investigations to intervene at enforcement proceedings and

to have notice of summonses issued in connection with an

investigation of his activities. Section 7609 does not explicitly

speak to the taxpayer's rights at the trial level, but the

legislative history suggests that even if a taxpayer chooses not

to intervene he may still raise his claims in a subsequent trial.

See text accompanying note 31 infra. Thus, assuming that a

taxpayer did not intervene at the investigatory stage,

suppression at trial would be the only remedy capable of ensuring

governmental compliance with § 7602.

[fn30] On January 17, 1975, prior to indictment, trial counsel

for Forman wrote to the IRS Special Agent investigating their

activities and requested that defendants be notified by the IRS

of any summonses it intended to serve so that he could challenge

them, if appropriate. On May 8, 1975, the Special Agent replied

by letter that he would not advise appellants of any summonses

issued to third parties. Nevertheless, the record of the

pre-trial proceedings suggests that appellants were aware of some

summonses prior to compliance and in time to attempt to institute

the stay and intervention procedures outlined in Reisman and

Donaldson. In the January 17, 1975, letter to the IRS, trial

counsel for Forman stated that he had advised one of the third

party banks not to comply with a summons dated January 13, 1975.

It appears that no judicial action was ever initiated to restrain

compliance. Moreover, on one occasion, counsel for Forman

attempted to attend physically an IRS interview of the

Corporation's accountant, who had been summoned to appear, but he

was asked to leave. On the whole, however, appellants maintain

that they had no knowledge of most of the summonses until after

compliance and stress that even at this late date they have no

precise indication as to whom and when all the summonses were

served.

[fn31] Similarly, one 1975 Congressional report, summarizing the

administrative procedures of the IRS prior to the 1976 Tax Reform

Act, states that "a taxpayer who either does not attempt to

intervene or restrain or who fails in his attempt may assert his

rights when the government subsequently attempts to use the

material against him." Report on Administrative Procedures of the

Internal Revenue Service to the Administrative Conference of the

United States (October 1975), 94th Cong., 2d Sess. 755 (emphasis

added).

[fn32] The government suggests that appellants may have waived

their right to an evidentiary hearing by failing to object to the

trial court's refusal of their request. The following colloquy

occurred at the hearing on defendants' motion to suppress.

"Mr. Zuckerman: Your honor, I don't know whether it is

appropriate or not, but in the event that there is error in any

of your Honor's ruling, would it be appropriate to have

evidential findings or to have a hearing before the trial in this

case as to what the facts were, what was secured after the 6(e)

order and what evidence was secured under the summonses after a

certain date? Because I think — I can see an Appellate Court

speculating as to what we are talking about?

"The Court: I know, I want to be fair. That is why I asked you

whether you wanted anything more on the record. But you see I am

in this position. It is very hard for me to make that kind of

record pre-trial without conducting a pretrial trial:

"Mr. Zuckerman: That's correct, sir.

"The Court: That would be a monumental waste of time in the

event of an acquittal.

"Mr. Zuckerman: I recognize that. It would be a monumental

waste of time for the Third Circuit to agree with you in the

event of a conviction.

"The Court: That's correct. If the Third Circuit disagrees with

me, they would have the option of remanding it back for an

evidential hearing on that limited question.

"Mr. Zuckerman: All right.

"The Court: I don't want to preclude you Does that make sense

to you?

"Mr. Zuckerman: It makes sense to me. I'm content for the

record to state that."

166a-168a (emphasis added).

However, in a letter to the trial judge dated August 16, 1976,

prior to entry of the order of September 9, 1976, denying

defendants' motion to suppress, Mr. Zuckerman explicitly renewed

his request for an evidentiary hearing. 198a. We think that under

the circumstances defendants properly voiced their objection and

preserved their right to appeal the trial judge's denial of an

evidentiary hearing.

[fn33] See Internal Operating Procedures for the United States

Court of Appeals for the Third Circuit, § L.

Page 706

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