OPINION
BOGGS, Circuit Judge.
The United States brought a civil action seeking to enjoin the defendants — Tobias H. Elsass ("Elsass") and two entities that he founded and controlled, Fraud Recovery Group, Inc. ("FRG") and Sensible Tax Services, Inc. ("STS") — from providing certain services to taxpayers on the grounds that the defendants had frequently engaged in practices that violate the tax laws. See 26 U.S.C. §§ 7402, 7407...
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