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ABRAHAM v. UNITED STATES

No. 1442, Docket 84-6101.

740 F.2d 2 (1984)

Alexander ABRAHAM, James R. Abraham, Miriam Abraham, Otto Abraham Trust, Peter DeHaas, Frederick Frank, Arthur Fried, Meryl Gallatin, Evelyn Gollomp, Fred Graber, Edmond A. Hajim, F. Warren Hellman, George Heyman, Jr., Allan B. Hunter, Bernard Laterman, David Leinbach, Arthur Magill, Paul Manheim, William H. Osborn, Andrew G.C. Sage, William Taft, Stuart Travis, Arthur Weigner, Sidney Winters, Petitioners-Appellants. v. UNITED STATES of America and James R. Borowski, Respondents-Appellees.

United States Court of Appeals, Second Circuit.

Decided July 18, 1984.

Attorney(s) appearing for the Case

Stephen D. Gardner, New York City (John Hartje, Ann-Elizabeth Purintun, Kronish, Lieb, Shainswit, Weiner & Hellman, New York City, on brief), for petitioners-appellants.

Gerald T. Ford, Asst. U.S. Atty., New York City (Rudolph W. Giuliani, U.S. Atty., Leona Sharpe Chamberlin, Asst. U.S. Atty., New York City, on brief), for respondents-appellees.

Before NEWMAN and PRATT, Circuit Judges, and KELLEHER, District Judge.

PER CURIAM:

This is an appeal from a judgment of the District Court for the Southern District of New York (Shirley Wohl Kram, Judge), dismissing a petition to quash two summonses issued by the Internal Revenue Service. The summonses were served upon Lehman Brothers Kuhn Loeb Inc. ("Lehman Trading") in connection with an audit of the tax liability of its corporate parent, Lehman Brothers Kuhn Loeb Holding Co. ("Lehman Holding...

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