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ABRAHAM v. UNITED STATES

No. 83 Civ. 1487 (SWK).

582 F.Supp. 257 (1984)

Alexander ABRAHAM, James R. Abraham, Miriam Abraham, Otto Abraham Trust, Peter De Haas, Frederick Frank, Arthur Fried, Meryl Gallatin, Evelyn Gollomp, Fred Graber, Edmund 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, and Sidney Winters, Petitioners, v. UNITED STATES of America and James R. Borowski, Respondents.

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

March 29, 1984.

Attorney(s) appearing for the Case

Kronish, Lieb, Shainswit, Weiner & Hellman, New York City, for petitioners; Stephen D. Gardner, John Hartje, New York City, of counsel.

Rudolph W. Giuliani, U.S. Atty., S.D. N.Y., New York City, for respondent; Gerald T. Ford, New York City, of counsel.

MEMORANDUM DECISION AND ORDER

KRAM, District Judge.

BACKGROUND

The above-captioned action came before this Court on the petition of the taxpayer-petitioners to quash two summonses served on Lehman Brothers Kuhn Loeb Inc. ("Lehman Trading") which required production of records of financial transactions of the petitioners. The summonses were issued by the Internal Revenue Service ("IRS") in furtherance of an audit of the tax liability of Lehman Brothers...

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