United States of America and Conley E. Lemons, Special Agent, Internal Revenue Service v. Al Johnson

LEWIS R. MORGAN, Circuit Judge:

In this appeal the Internal Revenue Service seeks review of an order by the District Court for the Southern District of Florida which modifies an order to enforce two Internal Revenue summonses.

I

The first summons in question, dated May 5, 1971, directed the respondent-appellee Al Johnson, an attorney, to appear before Special Agent Conley Lemons of the Internal Revenue Service on May 17, 1971, and to produce:

Documents contained in your files regarding the purchase, lease, and/or sale of real and personal property by TED NEELY.

Also, financial statements and…