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PAA MANAGEMENT, LTD. v. U.S.

No. 982, Docket No. 91-6275.

962 F.2d 212 (1992)

PAA MANAGEMENT, LTD., Petitioner-Appellee, v. UNITED STATES of America, Respondent-Appellant.

United States Court of Appeals, Second Circuit.

Decided April 27, 1992.

Attorney(s) appearing for the Case

Randall A. Hack, Chicago, Ill. (Barbara M. Angus, Kirkland & Ellis, of counsel), for petitioner-appellee.

David E. Sipiora, Asst. U.S. Atty., New York City (Otto G. Obermaier, U.S. Atty., Gabriel W. Gorenstein, Asst. U.S. Atty., of counsel), for respondent-appellant.

Before: FEINBERG and MINER, Circuit Judges, and HAIGHT, District Judge.

MINER, Circuit Judge:

Respondent-appellant United States of America appeals from an order of the United States District Court for the Southern District of New York (Knapp, J.). The order quashed administrative summonses, issued by the Internal Revenue Service ("IRS") pursuant to section 7602 of the Internal Revenue Code of 1986, 26 U.S.C. §§ 1 et seq. ("I.R.C." or "Code"), to petitioner-appellee PAA Management, Ltd. ("PAAM"), and to Arthur...

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