OPINION
CONTIE, Circuit Judge.
Petitioners-appellants, Ezekiel Clay IV, et al., appeal the judgment of the district court dismissing their petition to quash IRS summonses to a third-party recordkeeper because the petition was untimely filed. For the following reasons, we affirm.
I.
The Internal Revenue Service ("IRS"), pursuant to an income tax investigation of petitioner Clay and several trusts of which he is the trustee ("petitioners...
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