MEMORANDUM OPINION
BUE, District Judge.
This is an action instituted by the United States and Gerald T. Culver, Special Agent of the Internal Revenue Service, pursuant to 26 U.S.C. §§ 7604(a) and 7402(b) to enforce a summons served on Mr. White on December 7, 1970, requiring the production of records affecting his client, Mr. Roberts. These records consist of certain summaries and work papers prepared by Mr. Stanley H. Voelkel, an accountant, hired...
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