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UNITED STATES v. LINSTEADT

Nos. 83-1214, 83-1463 Summary Calendar.

724 F.2d 480 (1984)

UNITED STATES of America and Larry D. McLain, Plaintiffs-Appellees, v. L.A. LINSTEADT, as President, and Wannelle Linsteadt, as Vice President of Pronto, Inc., Defendants-Appellants. UNITED STATES of America, and Larry McLain, Plaintiffs-Appellees, v. NORTHEAST NATIONAL BANK, et al., Defendants, L.A. and Wannelle Linsteadt and Pronto, Inc., Intervenors-Appellants.

United States Court of Appeals, Fifth Circuit.

February 6, 1984.

Attorney(s) appearing for the Case

Tarlton, Douglas, Kressler & Wuester, William O. Wuester, Fort Worth, for defendants-appellants.

Mattie Nell Peterson Compton, Asst. U.S. Atty., Fort Worth, Tex., Michael L. Paup, Chief, Appellate Sect., Tax Div., U.S. Dept. of Justice, Glenn L. Archer, Jr., Asst. Atty. Gen., Charles E. Brookhart, George L. Hastings, Jr., Washington, D.C., for plaintiffs-appellees.

Before BROWN, TATE and HIGGINBOTHAM, Circuit Judges.

TATE, Circuit Judge:

Before us are two appeals from separate orders of the district court enforcing two sets of Internal Revenue Service ("IRS") summonses. 26 U.S.C. §§ 7602, 7604. Both orders enforced production of books, records, and other data sought by the IRS for the purpose of ascertaining the correct corporate and individual income tax liability of a corporation ("Pronto") and of its officers (the "Linsteadts"), who were husband and wife and also...

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