United States of America, and Ralph Scheidt, Special Agent of Internal Revenue Service v. Anun Seetapun, M.D., S.C., a Corporation

CUMMINGS, Chief Judge.

The government appeals from the district court’s discharge of its rule to show cause against Dr. Anun Seetapun and his wife Marcia Seetapun and its denial of an order for contempt against the corporation Anun Seetapun, M.D., S.C. We reverse and remand.

I

The litigation now before us began when the Internal Revenue Service (“IRS”) issued an administrative summons to Anun Seetapun, M.D., S.C. (the “Corporation”) on February 15, 1983. The Corporation is a medical service corporation through which Dr. Seetapun (“Anun”) engages in the practice of plastic surgery. The IRS…