REPORT AND RECOMMENDATION
PATRICIA A. SULLIVAN, Magistrate Judge.
Petitioners Carol Smith, Carol Smith, LLC and Carol Smith Nevada, LLC (collectively "Petitioners") initiated this federal proceeding by miscellaneous petition to quash a summons issued by the Internal Revenue Service ("IRS") to the Bank of Newport ("Bank"). The summons requested Petitioners' account records from the Bank in connection with a collection action against a taxpayer, with whom...
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