Opinion by Judge RYMER; Concurrence by Judge PREGERSON.
RYMER, Circuit Judge:
John Crystal, Victoria Crystal, and Crystal Pools, Inc. appeal summary judgment in favor of the government denying their petition to quash and ordering enforcement of third party summonses issued by the Criminal Investigations Division ("CID") of the Los Angeles District of the Internal Revenue Service. The Crystals initiated contact for a voluntary disclosure with the Southern California...
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