WIGGINS, Circuit Judge.
The Internal Revenue Service (IRS) seeks enforcement of a summons it issued to Kenneth S. Vallance to obtain the records of two corporations of which Vallance was an officer and principal owner at the time the summons was issued. Vallance appeared as required by the summons but refused to supply the records, claiming that the summons was overly broad. After the initial meeting, Vallance did not hear from the IRS concerning this matter for almost...
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