United States of America Cheryl L. Mosby, Revenue Agent for the Internal Revenue Service v. V-1 Oil Company Gene Baxter, Secretary

9 F.3d 1555 73 A.F.T.R.2d 94 -510 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. UNITED STATES of America; Cheryl L. Mosby, Revenue Agent for the Internal Revenue Service, Plaintiffs-Appellees, v. V-1 OIL COMPANY; Gene Baxter, Secretary, Defendant-Appellants. No. 92-36965. United States Court of Appeals, Ninth Circuit. Submitted Nov. 1, 1993. * Decided Nov. 10, 1993. Before: SCHOREDER, D.W. NELSON, and THOMPSON, Circuit Judges. 1 MEMORANDUM ** 2 V-1 Oil Company ("V-1") and its secretary, Gene Baxter, appeal the district court's order enforcing an Internal Revenue Service ("IRS") summons requesting the production of documents relevant to V-1's federal income tax liability for the tax years 1988 and 1989. We have jurisdiction under 28 U.S.C. § 1291 , and we affirm. 3 V-1 contends that the district court erred by enforcing the summons because V-1's payment in full of the tax assessment for the 1988 tax year prior to the judicial enforcement proceedings rendered moot…