Waller

MEMORANDUM **

William Waller appeals pro se from the district court’s order denying his petition to quash the Internal Revenue Service (“IRS”) summonses issued to twenty-four entities in an investigation of his tax liabilities for the years 1998 through 2004. We have jurisdiction under 28 U.S.C. § 1291 and 26 U.S.C. § 7609 (h)(1). We review for clear error the denial of a petition to quash an IRS summons and de novo the district court’s interpretation of a statute. Fortney v. United States, 59 F.3d 117, 119 (9th Cir.1995). We review for abuse of discretion the district court’s denial of Waller’s motion for reconsideration. Fireman’s Fund Ins. Cos. v. Alaskan Pride Pshp., 106 F.3d 1465 , 1470-71 (9th Cir.1997). We affirm.

The district court did not err when it concluded that Waller lacked standing to petition to quash the nineteen summonses issued to entities that are not third-party record keepers. A person has standing to petition to quash only if he/she is entitled under 26 U.S.C. § 7609 (a) to notice of issuance of a summons, and under 26 U.S.C. § 7609 (a)(2)(A) notice was required to be given to Waller only for summonses issued to third-party record keepers as defined by…