UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 96-1848

JOHN L. WILSON, JR.; CONSTANCE A. WILSON,

Petitioners - Appellants,

versus

UNITED STATES OF AMERICA; INTERNAL REVENUE SERVICE,

Respondents - Appellees.

No. 96-1889

JOHN L. WILSON, JR.; CONSTANCE A. WILSON,

Petitioners - Appellants,

versus

UNITED STATES OF AMERICA; INTERNAL REVENUE SERVICE,

Respondents - Appellees.

Appeals from the United States District Court for the Western Dis- trict of North Carolina, at Asheville. Lacy H. Thornburg, District Judge. (MISC-96-23-1-T)

Submitted: January 9, 1997 Decided: January 16, 1997 2 Before HALL and MICHAEL, Circuit Judges, and PHILLIPS, Senior Circuit Judge.

Affirmed by unpublished per curiam opinion.

John L. Wilson, Jr., Constance A. Wilson, Appellants Pro Se. Gary R. Allen, Charles Edward Brookhart, Alice Lizbeth Ronk, UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for Appellees.

Unpublished opinions are not binding precedent in this circuit. See Local Rule 36(c).

PER CURIAM:

Appellants appeal the district court's orders granting the

Respondents' motion for summary enforcement of a third party summons and denying Appellants' motion for a stay of enforcement

pending appeal. We have reviewed the record and the district

court's opinions and find no reversible error. Accordingly, we

affirm on the reasoning of the district court. Wilson v. United States, No. MISC-96-23-1-T (W.D.N.C. May 29 & June 7, 1996). We

dispense with oral argument because the facts and legal contentions

are adequately presented in the materials before the court and

argument would not aid the decisional process.

AFFIRMED

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