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DOE v. U.S. BY AND THROUGH DEPT. OF TREASURY

Misc. Nos. 90/998 to 90/1000.

777 F.Supp. 590 (1991)

John DOE, John Doe I, John Doe II through John Doe VIII, Petitioners, v. UNITED STATES of America, Acting By and Through the DEPARTMENT OF TREASURY, INTERNAL REVENUE SERVICE, KNOXVILLE, TENNESSEE, Respondent.

United States District Court, E.D. Tennessee, N.D.

May 23, 1991.

Attorney(s) appearing for the Case

Ralph E. Harwell, Harwell, Baumgartner & Willis, W. Thomas Dillard, Ritchie, Fels & Dillard, Knoxville, Tenn., and Goldstein, Goldstein & Hilley, San Antonio, Tex., for petitioners.

Jose Francisco DeLeon, U.S. Dept. of Justice, Tax Div., Washington, D.C., for respondent.

Hal D. Hardin, Nashville, Tenn., for amicus curiae Tennessee Bar Ass'n.

MEMORANDUM OPINION

JARVIS, District Judge.

These three petitions ask this court to quash summonses issued by the Internal Revenue Service (IRS) to the law firms of Ritchie, Fels & Dillard, P.C. and Harwell, Baumgartner & Willis, P.A. (hereinafter "the law firms"). The petitioners are unnamed clients of the two law firms and the petitions are said to arise under 26 U.S.C. § 7609. The two law firms...

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