OPINION
SWEET, District Judge.
This action is one of a series of related actions arising out of an Internal Revenue Service ("IRS") investigation of the tax liability of Dr. Aldo Gucci ("Gucci") and Gucci Shops, Inc. ("Gucci Shops") for the years 1979, 1980 and 1981. In connection with the investigation, the IRS issued a number of summonses to Chase Manhattan Bank, N.A. ("Chase") and Citibank, N.A. ("Citibank"), requesting production of financial records...
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