OPINION
BARRY, District Judge.
I. Facts
On November 28, 1984, Ralph Fucetola, III, Esquire, represented the Church of Human Potential, Inc. ("petitioner") in a real estate transaction involving property now known as 16 Colfax Avenue, in Wayne, New Jersey. Thereafter, on July 15, 1985, Mr. Fucetola was summoned as a third party recordkeeper by the Internal Revenue Service. Mr. Fucetola was required to appear before Thomas Vorsky, an officer...
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