Ryan v. United States, 379 U.S. 61 (1964). · Go Syfert
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Ryan v. United States, 379 U.S. 61 (1964). Cases Citing This Book View Copy Cite
127 citation events (4 in the last 25 years) across 26 distinct courts.
Strongest positive: State v. Davis (ncctapp, 1989-12-19)
Treatment trajectory · 1964 → 2026 · click a year to view as-of
1964 1995 2026
Top citers, strongest first. 13 distinct citers. How cited ↗
cited Cited "see" State v. Davis
N.C. Ct. App. · 1989 · signal: see · confidence high
See Ryan v. U.S., 379 U.S. 61, 13 .
examined Cited "see" United States v. French (3×)
N.D. Iowa · 1977 · signal: see · confidence high
See Ryan v. United States, 379 U.S. 61 , 85 S.Ct. 232 , 13 L.Ed.2d 122 (1964).
discussed Cited "see" United States v. Thomas E. Stanley
D.C. Cir. · 1972 · signal: see · confidence high
See note 12, supra. See generally Bowman v. United States, 85 S.Ct. 232 , 13 L.Ed.2d 171 (1964) (Mr. Justice Douglas); Carbo v. United States, 82 S.Ct. 662 , 7 L.Ed.2d 769 (1962) (Mr. Justice Douglas); Di Candia v. United States, 78 S.Ct. 361 , 2 L.Ed.2d 410 (1958) (Mr. Justice Harlan); Ward v. United States, 76 S.Ct. 1063 , 1 L.Ed.2d 25 (1956) (Mr. Justice Frankfurter); United States v. Jackson, supra note 14 , 135 U.S.App.D.C. at 208-210, 417 F.2d at 1155-1157 (1969); Weaver v. United States, 131 U.S.App.D.C. 388, 389 , 405 F.2d 353, 354 (1968); Byrd v. United States, 130 U.S.App.D.C. 277 , …
cited Cited "see" United States v. Benjamin J. Thompson
D.C. Cir. · 1972 · signal: see · confidence high
See Bowman v. United States, 85 S.Ct. 232 , 13 L.Ed.2d 171 (1964) (Mr. Justice Douglas, sitting as Circuit Justice); United States ex rel.
discussed Cited "see" Greene v. State
Fla. · 1970 · signal: see · confidence high
See Younghans v. State, 90 So.2d 308 (Fla. 1956) and Stalnaker v. State, 126 Fla. 407 , 171 So. 226 (1936). [3] Younghans v. State, 90 So.2d 308 (Fla. 1956). [4] Floyd v. State, 79 So.2d 778 (Fla. 1955). [5] See cases listed in Annots., 19 A.L.R. 807 (1922), 77 A.L.R. 1235 (1932), and 45 A.L.R. 458 (1926). [6] See, e.g., Bowman v. United States, 85 S.Ct. 232 , 13 L.Ed.2d 171 (1964); Sellers v. Georgia, 374 F.2d 84 (5th Cir.1967); United States ex rel.
examined Cited "see, e.g." McGreal v. AT & T Corp. (3×)
N.D. Ill. · 2012 · signal: see, e.g. · confidence low
See, e.g., Ryan v. United States, 379 U.S. 61, 62 , 85 S.Ct. 232 , 13 L.Ed.2d 122 (1964) (the IRS subpoena of an individual taxpayer’s records did not require probable cause); Doe v. United States, 253 F.3d 256, 264-65 (6th Cir.2001) (the administrative subpoena of a doctor’s professional, personal, and financial records was authorized by law and reasonably relevant).
discussed Cited "see, e.g." Parks v. FDIC
1st Cir. · 1995 · signal: see, e.g. · confidence medium
See, e.g., Ryan v. United States, 379 U.S. 61, 62 (1964) (upholding IRS summons to individual taxpayer "for the reasons given in United States v. Powell"); United States v. McAnlis, 721 F.2d 334, 336-37 (11th Cir. 1983), cert. denied, 467 U.S. 1227 (1984); United States v. Roundtree, 420 F.2d 845, 847-51 (5th Cir. 1969).
discussed Cited "see, e.g." Parks v. FDIC
1st Cir. · 1995 · signal: see, e.g. · confidence medium
See, e.g., Ryan v. United ___ ____ ____ ______ States, 379 U.S. 61, 62 (1964) (upholding IRS summons to ______ individual taxpayer "for the reasons given in United States v. _____________ Powell"); United States v. McAnlis, 721 F.2d 334, 336-37 (11th ______ ______________ _______ Cir. 1983), cert. denied, 467 U.S. 1227 (1984); United States v. _____ ______ _____________ Roundtree, 420 F.2d 845, 847-51 (5th Cir. 1969). _________ The Powell standard remains both the law of the land, ______ see, e.g., Tiffany Fine Arts, Inc. v. United States, 469 U.S. ___ ____ _________________________ __________…
examined Cited "see, e.g." United States of America and Simon Levin, Special Agent of the Internal Revenue Service v. Interstate Tool and Engineering Corporation (3×)
7th Cir. · 1975 · signal: see also · confidence low
See also United States v. Powell, 379 U.S. 48 , 85 S.Ct. 248 , 13 L.Ed.2d 112 (1964), and its companion case Ryan v. United States, 379 U.S. 61 , 85 S.Ct. 232 , 13 L.Ed.2d 122 (1964), cited by the Court in Donaldson v. United States, 400 U.S. 517, 526-27 , 91 S.Ct. 534 , 27 L.Ed.2d 580 (1971).
examined Cited "see, e.g." United States v. Zack (3×)
D. Nev. · 1974 · signal: see, e.g. · confidence low
See, e. g., United States v. Ryan, 320 F.2d 500 (6th Cir. 1963), aff’d, 379 U.S. 61 , 85 S.Ct. 232 , 13 L.Ed.2d 122 (1964); United States v. Monsey, 429 F.2d 1348, 1351 (7th Cir. 1970); and see Jaffe, The Ju *830 dicial Enforcement of Administrative Orders, 76 Harv.L.Rev. 865 (1963).
examined Cited "see, e.g." United States v. Albert Shlom (3×)
2d Cir. · 1969 · signal: see also · confidence low
See also Ryan v. United States, 379 U.S. 61 , 85 S.Ct. 232 , 13 L.Ed.2d 122 (1964); United States v. Powell, 379 U.S. 48 , 85 S.Ct. 248 , 13 L.Ed.2d 112 (1964); Oklahoma Press Pub.
examined Cited "see, e.g." United States v. Giordano (3×)
E.D. Mo. · 1969 · signal: see also · confidence low
See also, United States v. Ryan, 6 Cir., 320 F.2d 500 , aff’d 379 U.S. 61 , 85 S.Ct. 232 , 13 L.Ed. 2d 122 .
examined Cited "see, e.g." United States of America and Ralph L. Guyette, Special Agent, Internal Revenue Service v. John B. Harrington (3×)
2d Cir. · 1968 · signal: see also · confidence low
See also United States v. Ryan, 320 F.2d 500 (6th Cir. 1963), aff’d 379 U.S. 61 , 85 S.Ct. 232 , 13 L.Ed.2d 122 (1964).
Retrieving the full opinion text from the archive…
Ryan
v.
United States
12.
Supreme Court of the United States.
Nov 23, 1964.
379 U.S. 61
William R. Bagby argued the cause and filed briefs for petitioner., Bruce J. Terris argued the cause for the United States. On the brief were Solicitor General Cox, Acting Assistant Attorney General Jones, Joseph M. Howard and Norman Sepenuk.
Harlan, Stewart, Government, Douglas, Powell.
Cited by 54 opinions  |  Published
Mr. Justice Harlan

delivered the opinion of the Court.

In August 1961, Internal Revenue Agent Whelan issued a summons to taxpayer Ryan ordering him to pro-ducé his books for the years 1942 through 1953 inclusive. Ryan appeared but refused to produce the records, claiming that because tax liability for those years was long since barred except for fraud, [1] the agent had no right to examine the records unless he could show grounds for suspecting fraud.

The Government then instituted an enforcement proceeding in a federal district court pursuant to § 7402 (b) of the Internal Revenue Code of 1954. [2] The complaint alleged that on the basis of estimated net worth calcula[*62] tions the agent' strongly suspected fraud, and that examination of the records for the years in question was relevant and material in determining its existence. The taxpayer answered, putting the question of probable cause in issue, and, in addition, stating that he had not received the letter required by § 7605 (b) informing him that the Secretary or his delegate had determined the examination to be necessary. [3]

At the hearing the District Judge clearly indicated his opinion that the Government need not show probable cause for suspecting fraud, and ordered Ryan to produce those records which he had available. Although the hearing confirmed Ryan’s assertion that no “necessity letter” had been sent to him, the judge made no mention of this, probably because counsel did not press the point.

The Court of Appeals affirmed, 320 F. 2d 500, on the theory that no full-scale showing of probable cause need be made. Except for the records relating to the year 1945, which appeared to have been once previously examined, the court ruled that no necessity letter was required by § 7605 (b) because the Government had made no previous examination of those years.!

We granted certiorari, 376 U. S.. 904, on the only issue raised by petitioner, whether the Government must show probable cause for its examination of the records. [4] On that issue we sustain the judgment of the Court oT Appeals for the reasons given in United States v. Powell, decided today, ante, p. 48.

Affirmed.

Mr. Justice Stewart and Mr. Justice Golderg concur in the result, because they believe that through the[*63] testimony of Internal Revenue Agent Whelan a sufficient showing was made that the Government was not proceeding capriciously in this case. Me. Justice Douglas dissents for the reasons given in his separate opinion in United States v. Powell, ante, p. 59.
1

I. R. C., § 6501. See United States v. Powell, decided today, ante, p. 48, at p. 49, note 2.

2

See id., at p. 52, note 10.

3

See id., at p. 52.

4

The propriety of the court’s interpretation of the necessity letter requirement of § 7605 (b) is, therefore, not before us. See Trailmobile Co. v. Whirls, 331 U. S. 40, 48.