United States of America and Peter P. Calarco, Special Agent, Internal Revenue Service v. Daniel Millman, Esq.

GEORGE C. PRATT, Circuit Judge:

For the second time this case is before us on the government’s petition to enforce an Internal Revenue Service (IRS) summons directed against respondent Daniel Mill-man. On the earlier appeal, United States v. Millman, 765 F.2d 27 (2d Cir.1985) ("Millman I”), we reversed the district court’s order granting the government’s petition and remanded for an evidentiary hearing to determine whether the IRS summons was issued for an improper purpose. Id. at 30.

After the required hearing, the district court again ordered enforcement of the summons. Millman appeals again,…