Suggested Language to Obtain a Subpoena for Business Records

provided by Alan R. Graham
Senior Investigative Auditor
U.S. Treasury Department
Bureau of Alcohol, Tobacco, and Firearms

The following documents, records, and items in your position, custody, or control which relates directly or indirectly to, or which disclose information bearing directly or indirectly upon, the subject matter of the below listed paragraphs, for the period from _________________ , 19___ , through _________________ , 19___ , to include, but not limited to, the following for ______________________________:

1. All books of original entry and subsidiary records including but not limited to: general ledger, general journal, cash receipts journal, accounts receivable ledger, payroll journals and ledgers, purchase journal, shipping and receiving reports, and contingent liabilities.

2. Original source records, transaction summary reports, supporting records and documents, and informal workpapers related to, or resulting in entries made in the above noted books and records, including, but not limited to: bank records, purchase orders, delivery tickets, invoices, paid bills, loan files, and real property records.

3. Bank records for all known accounts, encompassing, but not limited to checking accounts, savings accounts, loans, lines of credit, and other financial instruments. These records would include bank statements, canceled checks, deposit tickets, check stubs and register, bank debit and credit memos, etc.

4. Articles of incorporation and corporate minutes; or any partnership agreements.

5. Correspondence files.

6. Reports and accountants' workpapers concerning preparation of financial records and reports and audits of the above named individual or business, to include, but not limited to: audited and unaudited financial statements (balance sheet, income statement, etc.), expense and revenue summaries, trial balances, changes in working capital, cash flow analysis, cost analysis, financial forecasts, and correspondence.

7. Tax returns; both Federal and State, sales, and employment tax returns with supporting schedules and workpapers. Also, amended returns, if any, and records of extensions, adjustments, and audits.

8. All insurance policies, records, and correspondence.

9. Any and all other information in your possession not specifically requested above.

Revised by Alan R. Graham (12/95)

reprinted by permission