Sovereign Bancorp Ltd. Seeks to Quash IRS Summonses

Sovereign Bancorp states that it is a Russian-authorized, closed joint stock company with limited convertibility, established in the Bahamas in 1990 for international venture capital and loan transactions. Sovereign states that it did have extensive business dealings with Olen Residential Realty and Olen Properties between 1991 and 1998. However, Sovereign states that it also had business dealings with a variety of other non-U.S. entities totally unrelated to Olen Residential Realty and Olen Properties. Sovereign states that it is the documents relating to its business with these other entities that is the core of its objection to the summonses.

Sovereign states that the documents requested by the IRS are irrelevant and immaterial to the Service's investigation of Olen Residential Realty and Olen Properties. Sovereign also states that the IRS failed to serve it with notices and copies of the summonses as required by section 7609(a). Sovereign further requests that to the extent the summonses are not entirely quashed, they should be limited to documents that specifically reference Olen Residential Realty and Olen Properties.

DATED: September 26, 2001