Court of Appeals for the Fifth Circuit September 11, 1981, No. 80-5024 (United States v. Southeast First National Bank of Miami Springs)

LEWIS R. MORGAN, Circuit Judge:

This is an appeal by the taxpayer from a district court order enforcing a summons issued by the Internal Revenue Service to taxpayer’s bank. The principal issue for review is whether the district court erred in denying taxpayer’s request for an adversary hearing on the question of whether the IRS issued the summons for an improper purpose.