William S. Green, Jr. v. United States

976 F.2d 736 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. William S. GREEN, Jr., Petitioner-Appellant, v. UNITED STATES of America, Respondent-Appellee. No. 91-35955. United States Court of Appeals, Ninth Circuit. Submitted Sept. 15, 1992. * Decided Sept. 22, 1992. Before GOODWIN, D.W. NELSON and REINHARDT, Circuit Judges. 1 MEMORANDUM ** 2 William S. Green, Jr. appeals pro se the district court's denial of his motion to quash an Internal Revenue Service ("IRS") summons served on a third-party recordkeeper and grant of the IRS's petition to enforce the summons. We have jurisdiction pursuant to 28 U.S.C. § 1291 and affirm. 3 * Background 4 The IRS issued its third-party summons as part of its investigation of Green's tax liability for tax years 1984 through 1989. Green sought to quash the summons. The district court denied his motion and granted the IRS's petition to enforce the summons. The summons directed Key Bank, the third-party recordkeeper, to produce various…