David E. Remark v. United States of America Internal Revenue Agent Fred L. Bridges

David Remark appeals pro se the district court’s order granting the Internal Revenue Service’s (IRS) motions to (1) enforce various third-party summonses issued by the IRS, and (2) dismiss Remark’s petition to quash the summonses. Remark contends the IRS failed to comply with the procedural requirements for issuing a summons. We have jurisdiction pursuant to 28 U.S.C. § 1291 . We review for clear error, United States v. Saunders, 951 F.2d 1065, 1066 (9th Cir.1991), and affirm.

The IRS issued third-party summonses to National Securities Corporation, Security Pacific Bank, and Seattle First National Bank during its investigation of Remark’s tax liability for the tax years 1982 through 1990. The summonses directed these entities to produce records pertaining to Remark’s bank accounts, wages, salaries, and other financial information. Remark filed a petition to quash the summonses; the IRS filed motions to dismiss Remark’s petition and to enforce the summonses. On November 18, 1991, the district court granted the IRS’s motion. On December 16, 1991, the court entered an order directing the summoned parties to appear before the IRS to testify and produce the requested records. On…