BOUDIN, Chief Judge.
John Berman appeals from the district court's order dismissing his motion to quash an administrative summons served by the Internal Revenue Service; the dismissal was based on the ground that the motion was not timely filed. The pertinent facts are undisputed.
From 1991 until 1999, Berman was a partner in the Boston law firm of Davis, Malm & D'Agostine ("the Davis firm"). He is the subject of an ongoing income tax investigation by...
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