PER CURIAM:
This is an appeal from a district court order enforcing an Internal Revenue Service (IRS) summons issued against Walter H. Pusch. Pusch is the creator and executive director of the Church of the Tolerants (Church), which is the subject of an IRS investigation to determine its potential income tax liability from 1972 to 1975 and its qualification for tax exempt status under I.R.C. § 501(c)(3).
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