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IP v. U.S.

205 F.3d 1168 (2000)

Sheila Ann IP, Petitioner-Appellant, v. UNITED STATES of America; Martin Lum Respondents-Appellees.

United States Court of Appeals, Ninth Circuit.

Filed March 7, 2000.

Attorney(s) appearing for the Case

Karen L. Hawkins, Taggart & Hawkins, San Francisco, California, for the petitioner-appellant.

Ellen P. DelSole, United States Department of Justice, Tax Division, Washington, D.C., for the respondent-appellant.

Before: ALDISERT, O'SCANNLAIN and HAWKINS, Circuit Judges.

Opinion by Judge ALDISERT; Concurrence by Judge O'SCANNLAIN.

ALDISERT, Circuit Judge:

The issue on appeal is whether notice is required under 26 U.S.C. § 7609(a) when the Internal Revenue Service summons a third-party record-keeper to produce financial records of a person who has no outstanding tax liability and who has no legal relationship with any person against whom a tax assessment has been made. Appellant Sheila Ann Ip had bank accounts in her own...

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