STIPULATION AND [PROPOSED] ORDER ON PETITION TO QUASH AN IRS SUMMONS

SUSAN ILLSTON, District Judge.

Respondent United States of America, and Petitioners Joseph and Emmy Liu (collectively, the "parties"), through their respective undersigned counsel of record, having engaged in discussions regarding resolution of the above-captioned matter, stipulate as follows and respectfully request an order pursuant to this stipulation.

IT IS HEREBY STIPULATED AND ORDERED THAT:

1. The Internal Revenue Service ("IRS") summons directed to Oplink Communications, LLC ("the Summons") dated September 14, 2017, has been narrowed by the IRS, including to cover only the time period 1999-2006.

2. This Summons, as narrowed by the IRS, is enforced and Oplink is to comply with the requests contained in the summons as narrowed by the IRS.

3. Based on the narrowing of the Summons by the IRS, petitioners no longer seek the relief sought in their Petition.

4. In light of this Stipulation, the Court vacates the hearing now scheduled for January 12, 2018, and the related briefing schedule.

5. Although no further relief is sought from this Court at this time, petitioners reserve the right to reopen this matter if the IRS seeks additional records from Oplink beyond those sought by the Summons as narrowed by the IRS.

ORDER

The above STIPULATED ORDER ON PETITION TO QUASH AN IRS SUMMONS is approved as the ORDER for this case and the parties shall comply with its provisions.

IT IS SO ORDERED.