MEMORANDUM OPINION
SCHATZ, District Judge.
This action is before the Court to enforce an Internal Revenue Service (IRS) summons pursuant to 26 U.S.C. §§ 7402(b) and 7604(a). The summons was served on the respondents, Barter Systems, Inc. (BSI) and Harry Hayter, president of BSI, on September 9, 1980. On April 8, 1981, an order was issued directing respondents to show cause why they should not be compelled to comply with the summons. A hearing was...
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