MEMORANDUM DECISION AND ORDER
LODGE, Chief Judge.
Pending before the court is a motion filed by Douglas Fitzgerald ("the respondent") for stay of order pending appeal. (Dkt. No. 16). For the reasons given below, the motion is granted.
Procedural Background.
The record reflects the following. On October 13, 1993, the government filed a petition to enforce three IRS summonses previously
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