MEMORANDUM AND ORDER
ELFVIN, District Judge.
Petitioners seek enforcement under 26 U.S.C. § 7402(b) and 7604(a) of an Internal Revenue Service ("IRS") summons issued in the course of an investigation into the income tax liabilities of Melbourne Concept, Inc. ("Melbourne") for tax years ended 1977 through 1980. Respondent Frank Critelli, Melbourne's President, is in possession of the summonsed items. In support of the Petition, Agent Govern submitted...
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