No. 82-2636.

709 F.2d 485 (1983)

UNITED STATES of America and William C. McCormick, Special Agent, IRS, Petitioners-Appellants, v. J. Martin LAWLESS, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided June 10, 1983.

Attorney(s) appearing for the Case

William A. Whitledge, Tax Division, Dept. of Justice, Washington, D.C., for petitioners-appellants.

Gregory A. Mescher, Vonachen, Cation, Lawless, Trager & Slevin, Peoria, Ill., for respondent-appellee.

Before BAUER and WOOD, Circuit Judges, and GRANT, Senior District Judge.

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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