MEMORANDUM OPINION AND ORDER
KRAM, District Judge.
The above-captioned action is before this Court upon the petition of Bernard Segmond ("taxpayer") to quash seven summonses issued by the Internal Revenue Service ("IRS"), described more fully below, and upon the cross-motion of the respondent to enforce those summonses. For the reasons discussed below, the petition is denied and the cross-motion is granted.
BACKGROUND
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