OPINION
GERRY, District Judge.
The Internal Revenue Service is investigating the extent to which certain clients of the law firm of Liebman & Flaster may have improperly claimed tax deductions for fees paid to the firm in connection with the acquisition of real estate partnership interests in the years 1978, 1979 and 1980.
No one disputes that the law firm did render certain services to a number of clients acquiring real estate partnership interests...
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