OPINION RE MOTION FOR ASSESSMENT OF ATTORNEY FEES
HILLMAN, District Judge.
This was originally an action to enforce an Internal Revenue summons issued by a revenue officer of the Internal Revenue Service (IRS) to respondent, Phillip B. Grable (taxpayer), pursuant to section 7602 of the Internal Revenue Code of 1954, 26 U.S.C. § 7602. The summons arose out of an investigation of the federal tax liability of the taxpayer for the years 1979 through 1982...
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