BREYER, Chief Judge.
The Internal Revenue Service, investigating the 1985, 1986, and 1987 tax liability of the Church of Scientology of Boston, has asked the district court to enforce a summons for church records. The district court refused to enforce the summons because, in its view, 1) the church records were not "necessary to determine the [church's tax] liability," 26 U.S.C. § 7611(b)(1)(A), and 2) the IRS had not issued the summons for a proper purpose....
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