Paul St. Paul v. United States of America A.J. Brau, Revenue Officer

996 F.2d 1227 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Paul ST. PAUL, Plaintiff-Appellant, v. UNITED STATES of America; A.J. Brau, Revenue Officer, Defendants-Appellees. No. 92-55556. United States Court of Appeals, Ninth Circuit. Submitted June 21, 1993. * Decided June 28, 1993. Before: CANBY, FERNANDEZ, and T.G. NELSON, Circuit Judges. 1 MEMORANDUM ** 2 Paul St. Paul appeals pro se the district court's dismissal of his petition to quash an Internal Revenue Service (IRS) third-party collection summons under 26 U.S.C. § 7609 , for lack of subject matter jurisdiction, and denial of his motion for reconsideration. We have jurisdiction under 26 U.S.C. § 1291 , and affirm. 3 "Denial of a petition to quash an IRS summons is reviewed under the clearly erroneous standard." Tornay v. United States, 840 F.2d 1424, 1426 (9th Cir.1988). 4 The IRS maintains broad powers to "summon information relevant to determine the liability of any taxpayer." 26 U.S.C. § 7602…