MEMORANDUM & ORDER
YOUNG, District Judge.
I. INTRODUCTION
The United States of America (the "United States") brings this petition on behalf of the Internal Revenue Service (the "IRS") to enforce an administrative summons served by the IRS on Zhong H. Chen ("Chen") pursuant to 26 U.S.C. section 7604(a). Pet. Enforce IRS Summons ("IRS Pet.") ¶ 1, ECF No. 1. In support of its summons, the IRS alleges that its request for documents...
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