OPINION AND ORDER
REYNOLDS, District Judge.
These actions were brought by the United States and James M. Bittman, a Special Agent of the Internal Revenue Service, pursuant to §§ 7402(b) and 7604 (a) of the Internal Revenue Code of 1954, to compel compliance with seven Internal Revenue summonses. All seven actions involve records concerning the same taxpayer, Donald A. Pollack. Counsel have agreed to consider issues common to the cases in one proceeding...
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