MEMORANDUM AND ORDER
FITZGERALD, Chief Judge.
This court issued an order on August 3, 1984 directing petitioner Caralyn Dean to show cause why this action should not be dismissed for lack of subject matter jurisdiction. Minute Order, August 3, 1984. Dean is petitioning to quash an Internal Revenue Service (IRS) summons directed to her employer from 1980-1983, Providence Hospital,
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