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  1. United States Of America And Robert Merlo, Revenue Agent,petitioners- Appellees, V. Samuels, Kramer And Company; First Western Governmentsecurities, Inc.; And The Individuals, Partnerships, Jointventures, Associations, Or Corporations, For Whom Samuels,kramer And Company And First Western Government Securities,inc., Acting As Principal, Agent And/or Broker Purchasedand/or Sold Any Financial Instruments Or Securitiesincluding Those Of Or Guaranteed By The United States Orunited States Government Corporations Or Agencies, Et Al.,respondents-appellants near Columbus, OH