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STEWART v. U.S.

No. 05-36112.

511 F.3d 1251 (2008)

Morse STEWART; Jeanine Stewart, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

Filed January 15, 2008.

Attorney(s) appearing for the Case

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

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.

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

O'SCANNLAIN, Circuit Judge:

We are called upon to determine whether a person who is not identified in an Internal Revenue Service administrative summons issued to a third party has standing to file a petition to quash.

I

Sometime in 2005, the Internal Revenue Service ("IRS") commenced an investigation of Morse Stewart's income tax liabilities for the tax years 1998 through 2003. In furtherance of that investigation, Revenue Agent Carla J. Oyala issued...

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