SUPERSEDING OPINION AND ORDER
PIERAS, District Judge.
The Court has before it petitioner's Motion to Quash Summons and opposition thereto, as well as the Motion for Summary Enforcement of Third-Party Record Keeper Summons and the opposition thereto.
Attached to the Respondent's Motion is a declaration by Mr. Norman F. Tancrell, special agent of the Internal Revenue Service (IRS), stating the purpose of the summons and the administrative status of...
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