OPINION
BROTMAN, District Judge.
An evidentiary hearing was held on March 31, 1992 and April 10, 1992 in this Internal Revenue Service ("IRS") summons enforcement matter. Petitioners, the United States and Joseph West, Revenue Agent of the IRS are investigating whether respondent, Frank Wheaton, Jr. ("Wheaton") has any federal income tax liabilities for the years 1981 through 1986 arising from his alleged control and/or ownership of three foreign corporations...
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