MEMORANDUM AND ORDER
KRUPANSKY, District Judge.
This action involves a petition by the Internal Revenue Service (IRS) to enforce an Internal Revenue Summons issued on City Bank (NKA AmeriTrust) and William Burchett (Burchett), Controller, under the authority of 26 U.S.C. § 7604. Defendants were requested to testify and produce documents allegedly necessary for the IRS to investigate the tax liability of one Thomas Kerr (Kerr) for the years 1977 (in...
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