MEMORANDUM AND ORDER
MILES W. LORD, Chief Judge.
This matter arises upon the motion of petitioners Gothic Evangelical Church and Homer and Louise Johnson to quash an Internal Revenue Service summons of records related to the Johnsons' potential tax liability for the years 1979-1983. Based upon the parties' pleadings, memoranda, affidavits and declarations, and upon the record developed at the evidentiary hearing held in open court on September 25, 1984,...
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