MEMORANDUM AND ORDER
ALLEN SHARP, Chief Judge.
I.
These actions are presently before the court on the second motion for show cause order of petitioners, United States of America (the Government), and William D. Lutgen, Revenue Agent, Internal Revenue Service (IRS) filed July 30, 1984.
The facts underlying this cause are as follows. The Government served summonses for tax information on respondents, Carter Family Trust, James R. Sattler...
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