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STUART v. U.S.

Nos. 85-4421, 86-3791.

813 F.2d 243 (1987)

Philip George STUART, Sr., Petitioner/Appellant, v. UNITED STATES of America, Respondent/Appellee. Mons KAPOOR, Petitioner/Appellant, v. UNITED STATES of America, Respondent/Appellee.

United States Court of Appeals, Ninth Circuit.

Decided March 24, 1987.

Attorney(s) appearing for the Case

Brian L. McEachron, Seattle, Wash., for the petitioner/appellant.

John A. Dudeck, Washington, D.C., for the respondent/appellee.

Before BROWNING, WRIGHT, and BOOCHEVER, Circuit Judges.

BOOCHEVER, Circuit Judge:

Stuart and Kapoor, citizens and residents of Canada, appeal the district court's denial of their petitions to quash summonses of records held by their bank in Bellingham, Washington. The Internal Revenue Service issued the summonses at the request of the Canadian Department of National Revenue, pursuant to Articles XIX and XXI of the 1942 Income Tax Convention with Canada.

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