United States of America and Gene E. Turley, Special Agent, Internal Revenue Service v. Stephen Jones, G. Maurene Townsend, Intervenor-Appellant

This controversy began when the government petitioned the district court under 26 U.S.C. §§ 7402(b) 1 and 7604(a) for judicial enforcement of an administrative summons issued by the Internal Revenue Service. The summons in question had been directed to an attorney [a third-party recordkeeper under 26 U.S.C. § 7609(a)(3)(E)] and sought information regarding his financial arrangements with a certain client who was the target of the IRS investigation.

Upon the filing of the government’s petition for enforcement, Judge Chandler directed the entry of an order designating Charles R. Jones, a…