BOWNES, Circuit Judge.
This is an appeal from an order of the United States District Court for the District of Massachusetts enforcing an administrative summons issued by the Internal Revenue Service (IRS) to appellant Reverend Richard M. Doncaster, pursuant to an investigation of the tax liability of appellant The Freedom Church, of which Reverend Doncaster is pastor. The action was filed pursuant to 26 U.S.C. §§ 7402(b)
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