MEMORANDUM OF DECISION
PLATT, District Judge.
On November 9, 1973 the Internal Revenue Service issued and served a summons on the respondents directing them to appear on November 27, 1973 at 10:00 a. m. at 120 Church Street, New York, New York, to testify and produce for examination "all accounts maintained by or for Manuel (Manny, Emanuel) Lo Porto and/or Mary Lo Porto:
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