In Donaldson v. United States, the Supreme Court explained that the civil rules apply to an IRS summons proceeding, but they do not apply inflexibly. 400 U.S. 517, 528, 91 S.Ct. 534, 541, 27 L.Ed.2d 580 (1971). Rather, “a district court, by local rule or by order, may limit the application of the rules in a summons proceeding ... so long as the rights of the party summoned are protected and an adversary hearing, if requested, is made available.” Id. at 528-29, 91 S.Ct. at 541. The Court in Donaldson approved limiting the application of Rule 24(a)(2), governing intervention as of right, in a tax summons case. Id. Subsequent cases have approved other limitations of the civil rules in IRS summons-enforcement cases. See, e.g., United States v. McCoy, 954 F.2d 1000, 1003-04 (5th Cir.1992) (<HOLDING>); United States v. Vetco, Inc., 691 F.2d 1281,
holding that notice to supervisor is notice to city holding that a defendant is not entitled to relief from default judgment because notice to an attorney of filing of motions and orders is constructive notice to the client even when the client did not have actual notice holding that notice of judgment was insufficient holding district court had discretion to modify the threeday notice requirement for default judgment by giving notice in a show cause order holding that actual notice fulfills a notice requirement that an applicable federal regulation be conspicuously posted because actual notice is the best notice