Willie Watts Mary Watts v. United States

52 F.3d 336 75 A.F.T.R.2d 95 -1731 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Willie WATTS; Mary Watts, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee. No. 94-56029. United States Court of Appeals, Ninth Circuit. Submitted April 4, 1995. * Decided April 7, 1995. Before: BROWNING, SNEED, and T.G. NELSON, Circuit Judges. 1 MEMORANDUM ** 2 Willie and Mary Watts appeal pro so the district court's order enforcing two Internal Revenue Service ("IRS") summonses issued to third-party record keepers for the purpose of determining their income tax liability for tax years 1989 through 1992. We have jurisdiction pursuant to 28 U.S.C. Sec. 1291 , and we affirm. 3 We review for clear error the district court's order enforcing an IRS summons. United States v. Derr, 968 F.2d 943, 945 (9th Cir.1992). 4 The Wattses contend that the district court lack subject matter jurisdiction to order enforcement of the summonses because (1) the statutory provisions…