Task: Wrong Candidate Generation
Input (English): OF THE COURT GREENBERG, Circuit Judge. I. JURISDICTION Thomas J. Capano appeals from an order entered in the district court on June 27,1997, holding that he waived the attorney work product privilege with respect to certain documents he created which the United States seized from a third party pursuant to a subpoena. The district court had jurisdiction under 18 U.S.C. § 3231, and we have jurisdiction to review the order of the district court pursuant to 28 U.S.C. § 1291. Cf. In re Grand Jury, 111 F.3d 1066, 1073-77 (3d Cir.1997) (<HOLDING>). II. FACTUAL AND PROCEDURAL HISTORY In July 
 Holding statements: (A) holding that a denial of an order to quash a subpoena not directed to a movant was a final order if the movant had no further opportunity to challenge the subpoena (B) holding that taxpayer who is the target but not the recipient of an administrative subpoena pursuant to 26 usc  7602 may challenge the subpoena (C) holding that denial of motion to vacate discovery order and to quash subpoena issued pursuant to 28 usc  1782 constitutes final appealable decision (D) holding that a denial of a motion to quash a grand jury subpoena is not final and therefore not appealable (E) holding that an order denying a motion to vacate a  1782 order and denying a motion to quash the subpoena was immediately appealable
Output (English): holding that taxpayer who is the target but not the recipient of an administrative subpoena pursuant to 26 usc  7602 may challenge the subpoena