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UNITED STATES v. SEETAPUN

No. 84-1538.

750 F.2d 601 (1984)

UNITED STATES of America, and Ralph Scheidt, Special Agent of Internal Revenue Service, Petitioners-Appellants, v. Anun SEETAPUN, M.D., S.C., a corporation, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided December 10, 1984.

Rehearing and Rehearing Denied January 11, 1985.

Attorney(s) appearing for the Case

John A. Dudeck, Jr., Asst. Atty. Gen., Tax Div., Dept. of Justice, Washington, D.C., for petitioners-appellants.

Michael Dockterman, Wildman, Harrold, Allen & Dixon, Chicago, Ill., for respondent-appellee.

Before CUMMINGS, Chief Judge, and BAUER, and POSNER, Circuit Judges.

Rehearing and Rehearing En Banc Denied January 11, 1985.

CUMMINGS, Chief Judge.

The government appeals from the district court's discharge of its rule to show cause against Dr. Anun Seetapun and his wife Marcia Seetapun and its denial of an order for contempt against the corporation Anun Seetapun, M.D., S.C. We reverse and remand.

I

The litigation now before us began when the Internal Revenue Service ("IRS") issued an administrative summons...

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