Mari Fleetwood v. United States of America Debra Ahn, I.R.S. Agent Paul Beene, I.R.S. Dist. Director

76 F.3d 386 77 A.F.T.R.2d 96 -939 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Mari FLEETWOOD, Plaintiff-Appellant, v. UNITED STATES of America; Debra Ahn, I.R.S. Agent; Paul Beene, I.R.S. Dist. Director, Defendants-Appellees. No. 95-35631. United States Court of Appeals, Ninth Circuit. Submitted Jan. 23, 1996. * Decided Jan. 26, 1996. Before: ALARCON, HALL and BRUNETTI, Circuit Judges. 1 MEMORANDUM ** 2 Mari Fleetwood appeals pro se the district court's dismissal as untimely of her motion to quash six third party recordkeeper summonses issued by the Internal Revenue Service. We have jurisdiction pursuant to 28 U.S.C. § 1291 , and we affirm. 3 When an IRS summons is issued to a third party recordkeeper, the taxpayer, as a person "entitled to notice of a summons" under 26 U.S.C. § 7609 (a), has twenty days from the date of notice to bring a proceeding to quash the summons. See 26 U.S.C. § 7609 (b)(2)(A); Ponsford v. United States, 771 F.2d 1305, 1309 (9th…