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PAA MANAGEMENT, LTD. v. U.S.

No. M24-1 (Part I) (WK).

817 F.Supp. 425 (1993)

PAA MANAGEMENT, LTD., Petitioner, v. The UNITED STATES of America, Respondent.

United States District Court, S.D. New York.

April 8, 1993.

Attorney(s) appearing for the Case

Melvin S. Adess, P.C., Garrett B. Johnson, Kirkland & Ellis, Chicago, IL, for petitioner.

David E. Sipiora, Asst. U.S. Atty., S.D.N.Y., New York City, for respondent.

OPINION AND ORDER

WHITMAN KNAPP, Senior District Judge.

I find myself in a rather unusual situation. Having conducted an evidentiary hearing upon remand from the Second Circuit in this action to quash five summonses issued by the Internal Revenue Service (PAA Management Ltd. v. U.S. (2d Cir.1992) 962 F.2d 212), and having considered arguments of counsel, I was in the process of preparing a memorandum in support of...

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