DUNIWAY, Circuit Judge:
Wang and Chen appeal from the district court order dismissing their petition to quash an Internal Revenue Service (IRS) summons issued to Whitfield Management Services. They argue (1) that Whitfield is a "third party recordkeeper" under 26 U.S.C. § 7609 and the summons was improper because they were not given notice, and (2) that as a "target" of a third party subpoena, they are independently entitled to intervene under general law principles...
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