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PAINE v. U.S. GOVERNMENT

No. Misc. 87-0182.

682 F.Supp. 739 (1987)

Lloyd N. PAINE, III, Bernd Hoffman, a.k.a. Phillip B. Paine, Petitioners, v. U.S. GOVERNMENT, Commissioner, Internal Revenue Service, Respondents.

United States District Court, E.D. New York.

November 9, 1987.

Attorney(s) appearing for the Case

Lloyd N. Paine and Bernd Hoffman, a.k. a. Phillip B. Paine, pro se.

Deborah S. Meland, Trial Atty., Tax Div., U.S. Dept. of Justice, Washington, D.C., for respondents.

MEMORANDUM AND ORDER

WEXLER, District Judge.

Petitioners Lloyd N. Paine III ("Paine") and Bernd Hoffman, a.k.a. Phillip B. Paine (collectively the "taxpayers") commenced this proceeding pursuant to 26 U.S.C. § 7609(b)(2)(A) to quash two Internal Revenue Service summonses (the "Summonses") issued by the United States to third-party record keepers in possession of certain of Paine's bank records. In response, the United States has moved, pursuant to the...

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