Daniel R. Thomas v. Patricia Wakefield, Irs Agent Internal Revenue Service United States of America

91 F.3d 155 78 A.F.T.R.2d 96 -5673 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Daniel R. THOMAS, Petitioner-Appellant, v. Patricia WAKEFIELD, IRS Agent; Internal Revenue Service; United States of America, Respondent-Appellees. No. 95-36237. United States Court of Appeals, Ninth Circuit. Submitted July 9, 1996. * Decided July 15, 1996. Before: HUG, Chief Judge, and SCHROEDER and POOLE, Circuit Judges. 1 MEMORANDUM ** 2 Daniel R. Thomas appeals pro se the district court's order denying his petition to quash a third-party recordkeeper summons issued to Key Bank of Oregon and enforcing the summons. We review for clear error, see Fortney v. United States, 59 F.3d 117, 119 (9th Cir.1995), and we affirm. 3 In order to establish a prima facie case for enforcement of a summons, the Internal Revenue Service need only make a "minimal" showing that the summons (1) was issued for a legitimate purpose, (2) seeks information relevant to that purpose, (3) seeks information that is not…