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UNITED STATES v. FOX

No. M-18-304(ADS).

554 F.Supp. 422 (1983)

UNITED STATES of America and Mary Jane Sciascia, Revenue Agent, Petitioners, v. Dr. Martin FOX, Respondent.

United States District Court, S.D. New York.

January 24, 1983.

Attorney(s) appearing for the Case

John S. Martin, Jr., U.S. Atty., S.D.N.Y., New York City, for petitioners; Stephen A. Dvorkin, New York City, of counsel.

Caplin & Drysdale, Washington, D.C., Stillman, Friedman & Shaw, New York City, for respondent; Richard E. Timbie, Scott D. Michel and Denise G. Shekerjian, New York City, of counsel.

MEMORANDUM OPINION AND ORDER

SOFAER, District Judge:

This case involves a petition by the Internal Revenue Service (IRS) to enforce a document summons served on the respondent taxpayer, Dr. Martin Fox. The summons called for production of three categories of documents:

1. All books and records, invoices, statements and other documents pertaining to the operation of the sole proprietorship of Dr. Martin Fox for the period January 1, 1979 to December...

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