MEMORANDUM OPINION AND ORDER
NORDBERG, District Judge.
On October 4, 1983, a hearing was held on the petition of the Internal Revenue Service ("IRS") to enforce a number of IRS summons issued against various financial institutions at which intervenor-taxpayers Robert L. Wenz and Merrick Consultants, Ltd. have accounts. These taxpayers have intervened in the summons enforcement proceeding pursuant to 26 U.S.C. § 7609(b)(1).
In United States...
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