MEMORANDUM OPINION
MENCER, District Judge.
The instant matter is before the Court on a petition to quash an I.R.S. summons, based on Fourth Amendment grounds, made by William R. Birdseye, et al. ("Birdseye"). The respondent, United States of America, Internal Revenue Service ("U.S. A.") made a motion to dismiss for lack of subject matter jurisdiction and a motion to enforce the summons. This Court concludes that pursuant to both 18 U.S.C. § 2518(10...
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