Wednesday, November 1, 2000
Volume:
16
Issue:
11
994
Abstract:
On December 1, 1999, the U.S. District Court for the Central District of California granted summary judgment to the U.S. Government to enforce an Internal Revenue Service (IRS) administrative summons issued on behalf of the French Government pursuant to an Income Tax Treaty.
The French Government requested information under the income tax treaty. On May 14, 1998, the IRS issued the summons for bank records held by Mitsui Manufacturers Bank (Mitsui) with respect to Lidas, Inc. and David and Liliane Chelala for the period of January 1, 1993 through December 31, 1994 pursuant to a request under Article 26 of the U.S.-French income tax treaty. The Chelalas reside in Brazzaville, the Republic of Congo...[more]