enforcement of the summonses.    The District Court

ordered Gallenberger, on behalf of PSAC, to appear before the IRS

by May 24, 1994, and produce the records sought by the summonses.

United States v. Administration Co., supra; Exh. 9047--Mem. Op.

and Ord. of May 20, 1994.

     Although Gallenberger appeared before the IRS and testified

and produced some documents on May 24, 1994, she did not search

all of the records in her possession but instead looked in every

fifth, sixth, or seventh file.    On June 10, 1994, the Government

filed with the District Court a motion to hold Gallenberger in

contempt.   On June 22, 1994, the District Court held a further

hearing.    The District Court noted that PSAC operated much like a

registered agent andTHC for 1983, 1984,

and 1985, Exhs. 148-150, and (2) partial trial balances of THC

for 1983 and 1984, Exhs. 161-162; Gallenberger, Transcr. at 2510-

2511.   There are no complete receipts and disbursement journals,

general ledgers, or trial balances for THC for 1980, 1981, 1982,

1985 (partial), 1986, 1987, 1988, and 1989.    Accordingly,

payments made by Schaffel, Frey, and Eulich/Essex Partnership to

THC are not traceable through THC’s books and records.

     Gallenberger had in her possession the records of THC for

1986, 1987, and 1988 and at some point turned those records over
                                 -221-

to Kanter.