OPINION
HILLMAN, Senior District Judge.
This is a proceeding brought pursuant to 26 U.S.C. § 7609(b)(2)(A) to quash four administrative summonses issued by the Internal Revenue Service. Two of the summonses were issued on October 23, 1998, and two were issued on October 26, 1998. The summonses were directed to Huntington Bank in Parma, OH; the CU Financial Group in Grand Rapids, MI; NBD Bank in Grand Rapids, MI; and Merrill Lynch Pierce Fenner...
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