FORREST P. TAYLOE

v.

UNITED STATES

Citator

Cited By (24 total)

• Donaldson v. United States, 400 U.S. 517 (U.S. 1971)
  …nt, that question appears to have been settled long ago when the Court upheld, against Fourth Amendment challenge, an internal revenue summons issued under the Revenue Act of 1921 and directed to a third-party bank. First Nat. Bank v. United States, 267 U. S. 576 (1925), aff’g 295 F. 142, 143 (SD Ala. 1924). See also United States v. First Nat. Bank, 274 F. Supp. 283, 284 (ED Ky. 1967), aff’d sub nom. Justice v. United States, 390 U. S. 199 (1968), and United States v. Shlom, 420 F. 2d 263, 266 (CA2 1969), c…
• California Bankers Assn. v. Shultz, 416 U.S. 21 (U.S. 1974)
  …ded long ago that an Internal Revenue summons directed to a third-party bank was not a violation of the Fourth-Amendment rights of either the bank or the person under investigation by the taxing authorities. See First National Bank v. United States, 267 U. S. 576 (1925), aff’g 295 F. 142 (SD Ala. 1924); Donaldson v. United States, supra, at 522. “[I]t is difficult to see how the shmmoning of a third party, and the records of á third party, can violate the rights of the-taxpayer, even if a criminal prosecutio…
• United States v. Miller, 425 U.S. 435 (U.S. 1976)
  …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 of Mobile v. United States, 267 U. S. 576 (1925), aff’g 295 F. 142 (SD Ala. 1924). See also California Bankers Assn. v. Shultz, supra, at 53; Donaldson v. United States, supra, at 522. Many banks traditionally kept permanent records of their depositors’ accounts, although not all banks did…

Authorities Cited

• Willard v. United States, 262 U.S. 489 (U.S. 1923)
• Brawley v. United States, 96 U.S. 168 (U.S. 1877)