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BARQUERO v. U.S.

No. 93-7447.

18 F.3d 1311 (1994)

Julio Roberto Zarate BARQUERO, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Counter-Claimant Appellee, v. INTERNATIONAL BANK OF COMMERCE, Counter-Defendant-Appellant.

United States Court of Appeals, Fifth Circuit.

April 20, 1994.

Attorney(s) appearing for the Case

Andy A. Tschoepe, II, John P. Guillory, Akin, Gump, Strauss, Hauer & Feld, L.L.P., San Antonio, TX, for plaintiff-appellant.

James P. Springer, Dept. of Justice, Tax Div., Gary R. Allen, Chief, Appellate Section, Charles E. Brookhart, Washington, DC, for appellee.

Before HENDERSON, SMITH, and EMILIO M. GARZA, Circuit Judges.

EMILIO M. GARZA, Circuit Judge:

Plaintiff Julio Roberto Zarate Barquero ("Zarate") and Counter-defendant International Bank of Commerce ("IBC") appeal the district court's order denying their motion to quash an administrative summons issued by the Internal Revenue Service ("IRS") and granting the government's motion to enforce the summons. We affirm.

I

In 1989, the United States and Mexico signed a Tax Information Exchange Agreement ("TIEA").

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