OPINION
RALPH B. GUY, Jr., District Judge.
Plaintiff instituted this suit seeking to quash an IRS summons that had been directed to Manley Bennett and Company, a stock brokerage firm with which plaintiff had engaged in financial transactions during the tax years 1977-1979. Specifically, plaintiff alleges that the summons was not issued in a good faith effort to determine his tax liability for the aforementioned years but instead was issued as part of an...
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