United States District Court, W.D. New York.
DECISION AND ORDER
ARCARA, District Judge.
INTRODUCTION
On May 20, 2003, petitioner filed the instant motion to enforce an Internal Revenue Service administrative summons seeking documents relative to Respondent's 1993, 1994, 1995 and 1996 individual and business tax returns. Respondent opposes the motion. Oral argument was heard on July 11, and August 29, 2003.
BACKGROUND1
In April,...
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