Merlin Hansen Dolores Hansen v. United States of America C. Frias, Revenue Officer T. Lapuh, Revenue Officer

999 F.2d 543 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Merlin HANSEN; Dolores Hansen, Petitioners-Appellants, v. UNITED STATES of America; C. Frias, Revenue Officer; T. Lapuh, Revenue Officer, Respondents-Appellees. No. 92-55284. United States Court of Appeals, Ninth Circuit. Submitted March 2, 1993. * Decided July 22, 1993. 1 Before: CHOY, GOODWIN, and SKOPIL, Circuit Judges 2 MEMORANDUM ** 3 Taxpayers Merlin and Dolores Hansen appeal the district court's dismissal of their pro se petition seeking to quash a third party IRS administrative summons. We agree with the government that the Hansens' notice of appeal was not timely filed. Accordingly, we dismiss the appeal for lack of jurisdiction. DISCUSSION 4 A timely filed notice of appeal is both mandatory and jurisdictional. Browder v. Director, 434 U.S. 257, 264 (1978). In this case there is no question that the notice of appeal was filed beyond the sixty days from entry of the district court's final order. See…