GRANT, Senior District Judge.
The Respondent-Appellee, J. Martin Lawless, an attorney in Peoria, Illinois, was retained by the co-executors of the estate to prepare the federal estate tax return of Edna E. Dieken, deceased. Petitioner-Appellant, Special Agent William C. McCormick, was assigned to investigate the correctness of the estate tax return. Summonses were issued to Lawless to testify regarding the tax return and to produce the following documents:
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