MEMORANDUM OPINION
THOMAS F. HOGAN, Chief Judge.
Pending before the Court is the United States of America's Petition to Enforce Internal Revenue Service Summonses. For the reasons set forth below, that Petition, as well as other relief, will be granted.
I. BACKGROUND / PROCEDURAL HISTORY1
As part of an Internal Revenue Service ("IRS") examination of KPMG's promotion
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