MEMORANDUM OPINION
MOTLEY, District Judge.
On November 6, 1978, this court heard oral argument by counsel for the government and the taxpayer concerning the Government's petition for enforcement of an administrative summons served on the Chase Manhattan Bank in connection with an IRS investigation of the taxpayer. The taxpayer, Joel M. White, had intervened pursuant to 26 U.S.C. § 7609(b)(1) on the grounds that the summons was not issued by the IRS...
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