MEMORANDUM-DECISION and ORDER
JAMES T. FOLEY, District Judge.
The United States of America and Richard R. Welcome, Special Agent of the Internal Revenue Service (IRS) filed petitions in the above proceedings on June 1, 1981, for an order directing the respondents to show cause why they should not be compelled to obey IRS summonses served upon them. These proceedings were brought pursuant to Title 26 U.S.C. §§ 7402(b) and 7604(a), to enforce judicially...
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