MEMORANDUM OPINION
ALLEN, District Judge.
This matter is before this Court upon petition of the United States pursuant to 26 U.S.C. Sec. 7402(b) and Sec. 7604 to judicially enforce an Internal Revenue Summons directing respondent (the attorney for the taxpayers) to appear to testify and to produce for examination certain books, records and papers presently in his possession. Motion by taxpayers, Albert Ray Neely and James Giles to intervene as individuals...
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