This argument also fails. "The summons provision of Title 26 has repeatedly sustained constitutional attacks based on the First, Fourth, and Fifth Amendments to the Constitution." Spine v. U.S., 670 F.Supp. 217, 221 (S.D. Ohio 1987). Thus, like the previous six reasons, Peterson's seventh basis for quashing the Summonses lacks merit.

This argument also fails. "The summons provision of Title 26 has repeatedly sustained constitutional attacks based on the First, Fourth, and Fifth Amendments to the Constitution." Spine v. U.S., 670 F.Supp. 217, 221 (S.D. Ohio 1987). Like the previous six, Peterson's seventh basis for quashing the summonses fails. IT IS THEREFORE ORDERED that:

Petitioner's argument that issuance of the summonses violates his rights under the Fourth Amendment of the Constitution is also flawed. "The summons provision of Title 26 has repeatedly sustained constitutional attacks based on the First, Fourth, and Fifth Amendments to the Constitution." Spine v. United States, 670 F. Supp. 217, 221 (S.D.Ohio 1987) (citations omitted). A person has no legitimate expectation of privacy in the contents of records voluntarily conveyed to a third-party.