Problem
On September 15, 20X0, Special Agent Iris Idlewild of the IRS issued a summons to Rudy Recordkeeper, a certified public accountant. The summons sought production of Recordkeeper's workpapers regarding Gilbert Giltiasin, who was then under examination. Within the time prescribed by law, Giltiasin took steps to prevent compliance by Recordkeeper.
On October 9, 20X0, Giltiasin files a petition to quash the summons with the District Court in the district in which Recordkeeper resides. On the same day, Idlewild called Recordkeeper and asked him how long it would take to assemble the records if the the court enforces the summons. Recordkeeper estimated that it would take approximately 100 hours to put together the records. Iris Idlewild asked Recordkeeper to begin assembling the records immediately so that if the court enforced the summons, there would not be a long delay before he could get the records. Must Recordkeeper comply with this request?