OPINION
TAKASUGI, District Judge.
Petitioners United States of America and Lawnie C. Mayhew, a Special Agent of the Internal Revenue Service, brought this action for enforcement of an Internal Revenue summons under §§ 7402(b) and 7604(a) of the Internal Revenue Code of 1954, 26 U.S.C. The summons, issued to respondent Jack Horton, demanded production of certain financial records and work papers of Schonert Construction Inc. [Schonert]. Mr. Horton...
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