United States of America, Plaintiff-Appellant-Cross-Appellee v. Author Services, Inc., Defendant-Appellee-Cross-Appellant

TANG, Circuit Judge:

The United States petitioned the district court to enforce an Internal Revenue Service (IRS) summons served on Author Services, Inc. (ASI) in connection with a criminal tax investigation of L. Ron Hubbard. 1 ASI contended the IRS was not acting in good faith and sought an evidentiary hearing to support that contention. ASI appeals from the district court’s denial of its request for an evidentiary hearing and from the enforcement order; the United States appeals from the district court’s restriction on the IRS’s use of the documents, prohibiting release of the documents to…