MEMORANDUM AND ORDER
HOLSCHUH, District Judge.
Petitioners Sam and Pat Spine bring this action against the United States, the IRS, and Randal S. Schneck, a special agent of the IRS. Petitioners seek to quash administrative summonses served by the IRS on Sears, J.C. Penney Co., Lazarus, Huntington National Bank, Diamond Savings & Loan, Society Bank, BancOhio National Bank, and Citizens Federal Savings & Loan, on the basis that these warrantless summonses...
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