Sabena Puri v. United States

NOT FOR PUBLICATION FILED

UNITED STATES COURT OF APPEALS AUG 22 2022

MOLLY C. DWYER, CLERK

U.S. COURT OF APPEALS

FOR THE NINTH CIRCUIT

SABENA PURI, No. 21-55132

Petitioner-Appellant, D.C. No. 2:20-cv-07270-RGK-AGR v.

UNITED STATES OF AMERICA, MEMORANDUM*

Respondent-Appellee.

Appeal from the United States District Court for the Central District of California R. Gary Klausner, District Judge, Presiding

Argued and Submitted March 9, 2022 Seattle, Washington

Before: NGUYEN, MILLER, and BUMATAY, Circuit Judges. Concurrence by Judge BUMATAY.

Sabena Puri appeals the district court’s order granting the government’s

motion to dismiss and denying her petition to quash an administrative third-party

summons issued by the United States Internal Revenue Service (“IRS”) to Citibank

N.A. for information relating to her bank accounts. The summons was issued at

the request of the tax authorities of the Republic of India pursuant to the

* This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3.…