MEMORANDUM OPINION AND ORDER
ROVNEP, District Judge.
I. INTRODUCTION
The United States of America (the "government") brought this case pursuant to 26 U.S.C. §§ 7402(b) and 7604(a) to obtain judicial enforcement of an Internal Revenue Service ("IRS") summons. The summons, addressed to Duncan personally and d/b/a Chicago Appraisers (a sole proprietorship), was served on January 22, 1987. The summons directed R. Bruce Duncan to appear before...
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