39

United States v. Holmes, 614 F.2d 985 (5th Cir. 1980). See also United States v. Trader's State Bank, 695 F.2d 1132 (9th Cir. 1983) (IRS summons seeking production of all of a church's bank statements, correspondence, and records relating to bank accounts, safe deposit boxes, and loans held to be overly broad).