TJOFLAT, Circuit Judge:
The United States appeals two district court orders granting a taxpayer's petitions to quash Internal Revenue Service (IRS) summonses. The district court gave the taxpayer such relief because it concluded that the summonses were issued for an improper purpose and were overbroad. We reverse.
I.
In the spring of 1983, Special Agent Bradford C. Vale of the Criminal Investigation Division of the Internal Revenue Service was assigned...
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