OPINION
FRANCIS J. BOYLE, Chief Judge.
PROCEDURAL BACKGROUND
Defendant has moved to suppress as evidence forty-five cartons of documents seized on the premises of Imperial Distributors on February 28, 1978. Defendant was indicted on December 8, 1981 and March 4, 1982, for various income tax offenses. The two indictments had been consolidated for purposes of a single trial.
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