OPINION ON CROSS-APPEAL
ALVIN B. RUBIN, Circuit Judge:
The United States appeals the district court's denial of the enforcement of its subpoena with respect to two documents described as "(1) letter from G. Booker Schmidt to Bill Jones and Lloyd Coppedge, dated January 21, 1981, consisting of five (5) pages; and (2) Memorandum addressing certain tax strategies, developed for use by Schmidt, consisting of sixteen (16) pages." The district court held that...
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