United States of America and Gerald R. Potocnak, Revenue Agent, Internal Revenue Service v. Pittsburgh Trade Exchange Inc. And Vincent E. Manella

OPINION OF THE COURT

GIBBONS, Circuit Judge.

Pittsburgh Trade Exchange, Inc. and Vincent E. Manella, its sole stockholder (collectively hereafter The Exchange) appeal from an order of the district court enforcing a “John Doe” summons served by the Internal Revenue Service. The appeal requires that we consider for the first time the appropriate standards for enforcement of “John Doe” summonses issued on the authority of section 1205(a) of the Tax Reform Act of 1976, Pub.L.94-455, 90 Stat. 1520, 26 U.S.C. § 7609(f). The Exchange contends that the court erred in several respects when it enforced…