DECISION AND ORDER
REYNOLDS, Chief Judge.
This is an action on a petition to quash an Internal Revenue Service summons served on a third party. This type of action was authorized only recently by the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub.L. No. 97-248, § 331, 1982 U.S. Code Cong. & Ad.News, No. 7, at 299.
On February 16, 1983, the respondent filed a response to the petition and a memorandum indicating that the petition...
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