MEMORANDUM
JOSEPH H. YOUNG, District Judge.
This is a proceeding brought under 26 U.S.C. §§ 7402(a) and (b), and 7604(a), to judically enforce an Internal Revenue summons which was served on the Darwin Construction Company, Inc. ("Darwin") on May 2, 1985. A hearing on the issues was held on March 25, 1986. The summons requested "(a)ll records or documents pertaining to the above corporation" for the period including 1980-1983. The summons also...
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