OPINION AND ORDER
SUSAN H. BLACK, District Judge.
This cause is before the Court on intervenor's Motion for Stay Pending Appeal, filed herein on May 10, 1982. Intervenor seeks a stay pending appeal of the Judgment entered herein on May 7, 1982, in which the Court ordered the enforcement, in part, of two civil Internal Revenue Service summonses.
I. STANDARD TO BE APPLIED
In order to evaluate the propriety of a stay in the instant action...
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