MEMORANDUM OPINION AND ORDER
FINESILVER, District Judge.
THIS ACTION is brought for judicial enforcement of two Internal Revenue Service [IRS] summonses issued pursuant to Section 7602 of the Internal Revenue Code of 1954, 26 U.S.C. § 7602, in furtherance of an IRS investigation into the correct income tax liabilities of Johns-Manville Corporation [J-M] for the years 1971 and 1972.
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