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PROVENZANO v. UNITED STATES

Civ. A. No. 83-0025.

569 F.Supp. 543 (1983)

Nunzio PROVENZANO and Angelina Provenzano v. UNITED STATES.

United States District Court, E.D. Pennsylvania.

August 4, 1983.

Attorney(s) appearing for the Case

Robert Fee, Paramus, N.J., Alan Tepper, Philadelphia, Pa., for petitioners.

Robert Gordon, U.S. Dept. of Justice, Washington, D.C., for defendant.

MEMORANDUM

CLIFFORD SCOTT GREEN, District Judge.

Now before the court is a petition filed by Nunzio and Angelina Provenzano, requesting the court to quash a subpoena issued by the Internal Revenue Service ("IRS"). Petitioners argue that the court should not enforce the summons because the statute of limitations bars its enforcement, the Commissioner of the IRS possesses the information which is the subject of the subpoena, and a "strict possession standard...

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