United States Ninth Circuit

A person who is not identified in an Internal Revenue Service administrative summons issued to a third party lacks standing to file a petition to quash.

Appellate Information

• Argued 12/06/2007
• Decided 01/15/2008
• Published 01/15/2008

Judges

• O'SCANNLAIN, Circuit Judge:, Before:  DIARMUID F. O'SCANNLAIN, SUSAN P. GRABER, and CONSUELO M. CALLAHAN, Circuit Judges.

Court

• United States Ninth Circuit

Counsel

• For Appellant:
  
• Morse and Jeanine Stewart, Vernonia, OR, filed briefs pro se as plaintiffs-appellants.


• For Appellees:
  
• Karen G. Gregory, Attorney, Tax Division, United States Department of Justice, Washington, DC, filed a brief for the defendant-appellee;  Frank P. Cihlar, Attorney, Tax Division, United States Department of Justice, Washington, DC, Eileen J. O'Connor, Assistant Attorney General, Tax Division, United States Department of Justice, Washington, DC, and Karin J. Immergut, United States Attorney, Portland, OR, were on the brief.