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UNITED STATES v. (UNDER SEAL)

No. 85-1121.

783 F.2d 450 (1986)

UNITED STATES of America, Appellee, v. (UNDER SEAL), Appellant. In re GRAND JURY 78-3 (John DOE NO. 218), Dr. Murdock Head, Airlie Trust, Airlie Foundation, and Raven's Hollow, Ltd.

United States Court of Appeals, Fourth Circuit.

Decided February 7, 1986.

Rehearing and Rehearing Denied March 24, 1986.

Attorney(s) appearing for the Case

Mitchell Rogovin, Washington, D.C. (Frank W. Dunham, Jr., Arlington, Va., on brief) for appellant.

William A. Whitledge, Washington, D.C. (Kenneth E. Melson, Asst. U.S. Atty., Arlington, Va., Michael L. Paup, Chief, Appellate Section, Glenn L. Archer, Jr., Asst. Atty. Gen., Robert E. Lindsay, Tax Div., U.S. Dept. of Justice, Washington, D.C. on brief) for appellee.

Before K.K. HALL and WILKINSON, Circuit Judges, and BUTZNER, Senior Circuit Judge.

Rehearing and Rehearing En Banc Denied March 24, 1986.

K.K. HALL, Circuit Judge:

Dr. Murdock Head and several business entities controlled by him, Airlie Foundation, Airlie Trust, and Raven's Hollow, Ltd., (the "taxpayers") appeal from the district court's order denying their motion to vacate a previous order which authorized disclosure of grand jury material to the Internal Revenue Service (the "IRS"). We affirm.

I.

In 1978, a federal grand...

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