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UNITED STATES v. NEW ENGLAND TEL. AND TEL. CO.

Misc. No. 83-026 P.

575 F.Supp. 138 (1983)

UNITED STATES of America, and John L. Toti, Jr., Special Agent Internal Revenue Service v. NEW ENGLAND TELEPHONE AND TELEGRAPH COMPANY and Joan Carrigan.

United States District Court, D. Rhode Island.

November 10, 1983.

Attorney(s) appearing for the Case

Lincoln C. Almond, U.S. Atty., R.I., Providence, R.I., Steven Toscher, Tax Div., U.S. Dept. of Justice, Washington, D.C., for petitioners.

OPINION

PETTINE, Senior District Judge.

The central issue here is whether or not the respondent, New England Telephone and Telegraph Company (New England Telephone) is a "third-party recordkeeper" within the meaning of Section 7609 of the Internal Revenue Code of 1954 (26 U.S.C.). For reasons which follow, I answer in the affirmative; the respondents need not comply with the summonses served upon them on October...

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