United States of America Mary Thomas, Revenue Officer v. Michael P. Tuuri

26 F.3d 135 74 A.F.T.R.2d 94 -5102 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel.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; Mary Thomas, Revenue Officer, Plaintiffs-Appellees, v. Michael P. TUURI, Defendant-Appellant. No. 93-16724. United States Court of Appeals, Ninth Circuit. Submitted May 16, 1994. * Decided June 3, 1994. Before: CHOY, SKOPIL, and FERGUSON, Circuit Judges. 1 MEMORANDUM ** 2 Michael Tuuri appeals pro se the district court's order enforcing an Internal Revenue Service (IRS) summons for appearance and production of books, records, papers, and other data relating to the determination of his tax liability for the 1989 and 1990 tax years. We affirm. 3 Tuuri first argues that the government did not prove the jurisdictional facts required by 26 U.S.C. Sec. 7401 . As this action is for the enforcement of a summons to appear and produce documents for the purpose of determining Tuuri's tax liability pursuant to 26 U.S.C. Sec. 7602 , rather than an action to collect taxes, 26…