Louis Stuart, Vivian Stuart and Rechel Stuart v. United States of America and Alson E. Lancaster, Special Agent, Etc.

DAVIS, Judge:

A summons, comparable to a subpoena duces tecum, was issued by the Internal Revenue Service, compelling appellant-taxpayers’ accountant, John B. Blois, to produce certain of their records in his possession. Blois resisted and the Service petitioned the court below for enforcement. Appellants were granted leave to intervene, under Rule 24(a) of the Federal Rules of Civil Procedure (“Intervention of Right”). From the order of the District Court enforcing the summons, they appeal.

In February 1968, Revenue Agent Alma Vaughn was assigned by the Service to conduct a civil investigation…