O'SCANNLAIN, Circuit Judge:
We must decide whether the conduct of the subject of a summons enforcement order obtained by the Internal Revenue Service may result in contempt and fines.
I
This appeal arises out of the lengthy and somewhat inept attempts by the Internal Revenue Service ("IRS") to compel testimony and the production of documents from Jose Vaz Ayres, a Varig Airlines Pilot and Brazilian citizen with a residence in Canoga Park, California...
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