OPINION AND ORDER
SUSAN H. BLACK, District Judge.
These cases came on upon the Petition to Quash Summons, filed herein on May 8, 1985. The government filed a Motion to Dismiss Petition to Quash and for Enforcement of Internal Revenue Service Summons on December 16, 1985, and petitioners' response in opposition was filed January 3, 1986. The Court heard oral argument on the petition and the motion on March 13, 1986.
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