the authority for which the section provides is being abused.” The government has provided no basis upon which to distinguish the reasoning of In re Letter of Request. In addition, that reasoning finds support in decisions of at least one other circuit and the Supreme Court. See In re Letter Rogatory from Justice Court, 523 F.2d 562, 563-64 (6th Cir. 1976) (“Although it is well-established that records of account belong to the bank and that a depositor may not prevent their disclosure on [F]ourth or [F]ifth Amendment grounds, it does not follow that appellant lacks standing to challenge the district court’s power to issue á subpoena under the terms of an authorizing statute.” (citations omitted)); see also Reisman v. Caplin, 375 U.S. 440, 449, 84 S.Ct. 508, 11 L.Ed.2d 459 (1964) (<HOLDING>). Consequently, the Court concludes that the
holding that taxpayer who is the target but not the recipient of an administrative subpoena pursuant to 26 usc  7602 may challenge the subpoena holding that a denial of an order to quash a subpoena not directed to a movant was a final order if the movant had no further opportunity to challenge the subpoena holding that because a grand jury subpoena issued through normal channels is presumed to be reasonable  the burden of showing unreasonableness must be on the subpoena recipient who seeks to avoid compliance but recognizing that a court may be justified under some circumstances in requiring the government to reveal the general subject of the grand jurys investigation before requiring the challenging party to carry its burden of persuasion holding that while a grand jury subpoena for the production of books and papers may implicate the fourth amendment when presented with a challenge to such a subpoena a court need only determine whether the request is far too sweeping in its terms to be regarded as reasonable holding that the term timely should be read in conjunction with 45c2b that requires a party subject to a subpoena to object to a subpoena duces tecum within 14 days of service of the subpoena