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U.S. v. ROCKWELL INTERN.

Nos. 88-3852, 89-3009.

897 F.2d 1255 (1990)

UNITED STATES of America and Robert G. Hackett, Special Agent of the Internal Revenue Service, Appellants/Cross-Appellees, v. ROCKWELL INTERNATIONAL, Appellee/Cross Appellant. Appeal of UNITED STATES of America and Robert G. Hackett, in No. 88-3852. Appeal of ROCKWELL INTERNATIONAL, in 89-3009.

United States Court of Appeals, Third Circuit.

Decided March 12, 1990.

Attorney(s) appearing for the Case

James I.K. Knapp, Acting Asst. Atty. Gen., Charles E. Brookhart (argued), Gary R. Allen, and Janet A. Bradley, Tax Div., Dept. of Justice, Washington, D.C., for appellants/cross appellees.

Joseph A. Katarincic (argued), Katarincic, Salmon & Steele, Pittsburgh, Pa., for appellee/cross appellant.

Before HIGGINBOTHAM, BECKER and NYGAARD, Circuit Judges.

OPINION OF THE COURT

BECKER, Circuit Judge.

This opinion addresses cross appeals by the United States and Internal Revenue Service Special Agent Robert Hackett, and by Rockwell International Corporation, from an order of the district court granting in part and denying in part the government's petition to enforce an Internal Revenue Summons served on Rockwell. The order placed conditions upon the enforcement of a summons for certain tax accrual papers known...

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