ORDER
EDENFIELD, Chief Judge.
I. BACKGROUND
Before the Court is the motion of the Internal Revenue Service (IRS) to enforce an IRS summons resisted by attorney A.G. Wells, Jr. According to IRS agent Kathleen Vaught, Wells and his wife failed to file federal income tax returns for 1990, 1991 and 1992. Upon being contacted by the IRS, Wells filed for those years but an IRS audit ensued. In June, 1995, Vaught subpoenaed...
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