MEMORANDUM AND ORDER
JAMES R. MILLER, Jr., District Judge.
On September 12, 1984, Internal Revenue Agent Gregory Szczeszek issued a summons to the Mercantile Safe Deposit and Trust Co. seeking the records of Jerome and Vera Dorsey, persons whose tax liabilities he was assigned to investigate (Paper No. 3, Affidavit of Szczeszek). Pursuant to 26 U.S.C. § 7609, Jerome and Vera Dorsey, on October 2, 1984, initiated this action to quash that summons (Paper...
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