OPINION
QUIST, District Judge.
Petitioner filed a motion to quash Internal Revenue Service (IRS) summonses issued to financial institutions requesting information regarding petitioner's accounts. The gravamen of petitioner's motion alleges that the IRS issued the summonses without lawful authority and without due process of law. Respondent filed a motion for summary denial of petitioner's motion to quash and for enforcement of the IRS summonses pursuant...
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