Allen M. Nelson Jo Ann M. Nelson, Husband and Wife v. United States

53 F.3d 339 75 A.F.T.R.2d 95 -1973 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Allen M. NELSON; Jo Ann M. Nelson, husband and wife, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee. No. 94-15632. United States Court of Appeals, Ninth Circuit. Submitted April 19, 1995. * Decided April 27, 1995. Before: BROWNING, SNEED and T. G. NELSON, Circuit Judges. 1 MEMORANDUM ** 2 Taxpayers Allen M. Nelson and Jo Ann M. Nelson appeal pro se the district court's order enforcing twelve third-party administrative summonses. We have jurisdiction, 28 U.S.C. Sec. 1291 , and affirm. I. 3 Revenue Agent Brian D. Juster was assigned to examine the taxpayers' 1990 and 1991 federal income tax returns. After several unsuccessful efforts to obtain relevant documents directly from the taxpayers, he served third-party summonses on eleven financial institutions and one consumer reporting agency. Taxpayers filed a petition to quash the summonses. The government moved for…