PIERCE, Circuit Judge:
The United States of America and James M. Serling, an estate tax attorney in the Internal Revenue Service ("IRS" or the "government"), appeal from a judgment of the United States District Court for the Western District of New York, Michael A. Telesca, Judge, which denied appellants' petition for an order enforcing two IRS summonses issued to the respondent, James M. White, an attorney. United States v. White,
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