Strough

ORDER APPROVING AND ADOPTING REPORT AND RECOMMENDATION OF UNITED STATES MAGISTRATE JUDGE

Pursuant to 28 U.S.C. § 636 , the Court has reviewed the file, including the Magistrate Judge’s Report and Recommendation, de novo.

IT IS ORDERED THAT: (1) the Report and Recommendation is approved and adopted; (2) the Petition is denied; (3) the third-party identified in the summons is directed to produce all requested records to the IRS forthwith; and (4) Judgment shall be entered dismissing this action with prejudice.

IT IS FURTHER ORDERED that the clerk shall serve a copy of this Order and the Judgment on all counsel or parties of record.

REPORT AND RECOMMENDATION OF UNITED STATES MAGISTRATE JUDGE

This Report and Recommendation is submitted to the Honorable David O. Car ter, United States District Judge, pursuant to 28 U.S.C. § 636 . For the reasons reported below, the Magistrate Judge recommends that the Court deny the Petition to quash the summons (“Petition”), direct the third-party identified in the summons to produce all requested documents to the Internal Revenue Service (“IRS”) forthwith, and dismiss this action with prejudice.

I. BACKGROUND

By way of her Petition, petitioner…