MEMORANDUM OPINION AND ORDER
SHADUR, District Judge.
In this action the United States and Internal Revenue Service ("IRS") Revenue Agent John Pelican ("Pelican") (collectively "petitioners") seek enforcement of an IRS summons issued to I.C. Industries, Inc. ("Industries") and its president and chief operating officer Robert F. Schnoes (collectively "respondents"). Respondents have moved to quash the summons, and petitioners in turn have moved for summary...
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