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CAVALLARO v. U.S.

No. 99-CV-12625-PBS.

153 F.Supp.2d 52 (2001)

William and Patricia CAVALLARO, Petitioners, v. UNITED STATES of America, Respondent.

United States District Court, D. Massachusetts.

July 27, 2001.

Attorney(s) appearing for the Case

William H. Paine, Jason S. Gerlach, Hale & Dorr, Boston, MA, for William Cavallaro, Patricia Cavallaro, Petitioners.

John Lindquist, U.S. Dept. of Justice, Tax Division, Ben Franklin Station, Washington, DC, Susan M. Poswistilo, United States Attorney's Office, Boston, MA, for USA, Respondent.

MEMORANDUM AND ORDER

SARIS, District Judge.

I. INTRODUCTION

This action involves an Internal Revenue Service ("IRS") proceeding to determine the correct tax liability of petitioners William and Patricia Cavallaro ("the Cavallaros") for the years 1987 through 1996. The IRS has issued a third-party record-keeper summons to the accounting firm of Ernst & Young seeking documents the accounting firm created or received while...

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