United States v. Clover Jean Holloway

37 F.3d 1507 74 A.F.T.R.2d 94 -6666 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel.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, Plaintiff-Appellee, v. Clover Jean HOLLOWAY, Defendant-Appellant. No. 94-15702. United States Court of Appeals, Ninth Circuit. Submitted Oct. 4, 1994. * Decided Oct. 6, 1994. Before: BROWNING, FARRIS, and LEAVY, Circuit Judges. 1 MEMORANDUM ** 2 Clover Jean Holloway appeals pro se the district court's order (1) enforcing the Internal Revenue Service's ("IRS") summons requesting the production of documents relevant to Holloway's federal income tax liability for the tax years 1989, 1990 and 1991, (2) denying Holloway's motion to quash, and (3) awarding costs to the United States. We have jurisdiction pursuant to 28 U.S.C. Sec. 1291 , and we affirm. 3 Holloway contends that the district court erred by enforcing the IRS's summons and denying her motion to quash because the IRS did not establish a prima facie case under United States v. Powell, 379 U.S. 48 (1964) and lacked…