MEMORANDUM OPINION AND ORDER
DAVID V. O'BRIEN, District Judge.
This petition asks us to enforce a tax summons for documents involving a lawyer's escrow account. We find that these documents are not privileged and that the law firm has failed to make a substantial showing that the Government ordered production in bad faith. The summons will, therefore, be enforced.
I. FACTS
On November 25, 1986, the Virgin Islands Bureau of Internal Revenue...
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