Nos. 72-2468, 72-2469.

485 F.2d 1165 (1973)

UNITED STATES of America et al., Petitioners-Appellees, v. Taylor MOORE and John Browne, Respondents-Appellants, Sebastian J. Mirelez, Intervenor-Appellant. UNITED STATES of America and Jack Hollenshead, Jr., Special Agent, Internal Revenue Service, Petitioners-Appellees, v. Dougal C. POPE and Sebastian J. Mirelez, Respondents-Appellants.

United States Court of Appeals, Fifth Circuit.

November 2, 1973.

Attorney(s) appearing for the Case

Taylor Moore, Charles E. Orr, John J. Browne, Houston, Tex., for respondents-appellants.

Theo W. Pinson, III, Mary L. Sinderson, James R. Gough, Asst. U. S. Attys., Anthony J. P. Farris, U. S. Atty., Houston, Tex., John M. Dowd, Atty., Scott P. Crampton, Asst. Atty. Gen., Tax Div., Meyer Rothwacks, Chief, Appellate Section, Robert E. Lindsay, Atty., Dept. of Justice, Washington, D. C., for petitioners-appellees.

Before ALDRICH, SIMPSON and CLARK, Circuit Judges.

ALDRICH, Senior Circuit Judge:

These appeals from orders enforcing summonses issued under 26 U.S.C. § 7602, although briefed by appellants in documents well-fitting the name, are not without some superficial difficulties.1

In April 1972, Nettle, a special agent of the Intelligence Division of the Internal Revenue Service, filed a petition in the district court naming Moore and Browne, (hereafter, for convenience, simply Moore...

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