United States v. Evelyn B. Hamilton, as Business Manager for Rbm Leasing Co., in the Matter of John Does, Etc.

BY THE COURT:

Appellant’s motion for stay pending appeal of the district court’s April 2, 1992, order is denied. The court’s order enforces the Internal Revenue Service’s (IRS) sum mons requiring the appellant to appear, to testify, and to produce certain records, papers, and other data in her possession relevant to the determination of the tax liabilities of certain John Doe taxpayers. Appellant appeals that order contesting the court’s determination that she is barred from challenging the IRS’ compliance with the statutory provisions authorizing issuance of the summons, under 26 U.S.C. §…