United States of America and Anthony Carsanaro, Revenue Agent, Internal Revenue Service v. The Freedom Church and Reverend Richard M. Doncaster

BOWNES, Circuit Judge.

This is an appeal from an order of the United States District Court for the District of Massachusetts enforcing an administrative summons issued by the Internal Revenue Service (IRS) to appellant Reverend Richard M. Doncaster, pursuant to an investigation of the tax liability of appellant The Freedom Church, of which Reverend Don-caster is pastor. The action was filed pursuant to 26 U.S.C. §§ 7402(b) 1 and 7604(a). 2 . Jurisdiction on appeal is based on 28 U.S.C. § 1291. See Reisman v. Caplin, 375 U.S. 440, 445-46, 84 S.Ct. 508, 11 L.Ed.2d 459 (1964).

There are three…