Order Denying Petition to Quash and Granting Cross-Petition to Enforce IRS Summonses
JAMES V. SELNA, District Judge.
Petitioner, Sterling Trading, LLC ("Sterling Trading") petitions this Court to quash the third-party summons served on Jimmy B. Summitt ("Summitt") by Respondent, United States of America, Department of the Treasury, Internal Revenue Service ("IRS"). The IRS counterpetitions to enforce the summons.
I. Background
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