ORDER OF SUMMARY JUDGMENT
MARCUS, District Judge.
THIS CAUSE is before the Court on the parties' Cross-Motions for Summary Judgment. At issue in this action challenging seven (7) tax summonses is whether the Petitioner, Donald Panton ("Panton"), can contest the underlying merits of a pending tax investigation, in the instant summons enforcement proceeding. Since we answer this question in the negative, we accordingly grant summary judgment in favor of the...
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