MEMORANDUM OPINION AND ORDER
JOINER, District Judge.
This is an action for judicial enforcement of an administrative summons issued by the Internal Revenue Service (IRS). Jurisdiction is proper under 26 U.S.C. §§ 7402(b), 7604(a). The pleadings, petitioner's affidavit, exhibits, and testimony adduced at the show cause hearing in this case disclose the following facts.
Petitioner James Budde, a special agent assigned to the Intelligence...
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