ORDER
JOINER, District Judge.
This matter is before the Court on the respondent's motion to dismiss the petition to quash an IRS summons. The motion has been considered on the papers filed and without oral argument pursuant to Fed.R. Civ.P. 78 and Local Rule 17(j).
Congress recently changed the procedures for challenging Internal Revenue summons issued to statutory third-party recordkeepers when it enacted the Tax Equity and Fiscal Responsibility...
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