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UNITED STATES v. PORTER

No. 81 C 2851.

557 F.Supp. 703 (1982)

UNITED STATES of America and Gerald T. Padar, Petitioners, v. Helen V. PORTER and Nickolaus Beligratis, Respondents.

United States District Court, N.D. Illinois, E.D.

On Motion for Reconsideration December 30, 1982.

Supplement to Memorandum Opinion and Order February 3, 1983.

Attorney(s) appearing for the Case

Dan K. Webb, U.S. Atty., Kevin J. Egar, Asst. U.S. Atty., Chicago, Ill., Robert G. Nath, Tax Div., U.S. Dept. of Justice, Washington, D.C., for petitioners.

Helen V. Porter, for Nickolaus Beligratis.

Lewis M. Porter, Boodell, Sears, Surgrue, Giambaluo & Crowley, Chicago, Ill., for Helen V. Porter.

FINDINGS OF FACT AND CONCLUSIONS OF LAW

SHADUR, District Judge.

In this action the United States and Internal Revenue Service ("IRS") Special Agent Gerald T. Padar ("Padar") (collectively "Petitioners") seek enforcement of three IRS summonses, one issued to Nickolaus Beligratis ("Beligratis") and the other two to Beligratis' attorney, Helen Viney Porter ("Porter") (Beligratis and Porter are collectively "Respondents"). This Court has conducted an evidentiary...

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