CHESNUT, District Judge.
The petitioner in this case is the Commissioner of Internal Revenue; and the respondents are the administrators of LeRoy L. Andrews, Deceased, and Henry C. Evans, as a member of the firm of Stein Bros. & Boyce, stock brokers of Baltimore. The jurisdiction of the court is based on United States Code Annotated, title 26 (revised) § 1523, which provides as follows:
"(a) To enforce summons. If any person is summoned under...
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