United States of America and Jim White, Jr., Special Agent, Internal Revenue Service v. Margie Wylie, Willie F. Baker, Intervenor-Appellee

R. LANIER ANDERSON, III, Circuit Judge:

Pursuant to a tax investigation of Willie Frank Baker, Internal Revenue Service Agent Jim White issued an administrative summons to bookkeeper Margie Wylie, directing that she produce documents relating to Baker’s alleged tax liabilities. Baker informed Wylie not to comply with the summons. See 26 U.S.C.A. § 7609(b)(2) (Supp.1983).

This action to enforce the summons was initiated in the United States District Court for the Middle District of Alabama. See 26 U.S.C.A. §§ 7402(b), 7604(a) (West 1967). On April 5, 1983, the court issued an order quashing the…