Schulz

MEMORANDUM **

Robert L. Schulz appeals pro se from the district court’s order denying his petition to quash a third party summons directed at PayPal in connection with an investigation of Schulz’s internet tax evasion scheme. We have jurisdiction pursuant to 28 U.S.C. § 1291 . The district court’s decision to enforce an IRS summons will not be disturbed unless its finding that the summonses were issued for a proper purpose was clearly erroneous. Ponsford v. United States, 771 F.2d 1305, 1307 (9th Cir.1985). The district court’s denial of a motion to reconsider is reviewed for abuse of discretion. Sch. Dist. No. 1J, Multnomah County, Or. v. ACandS, Inc., 5 F.3d 1255, 1262 (9th Cir.1993). We affirm.

The district court’s determination upholding the summons was not clearly erroneous. The IRS submitted a declaration establishing a prima facie case that the summons was issued in good faith as part of a legitimate investigation concerning Schulz’s tax liabilities and his role in assisting others in evading federal income tax laws. See Fortney v. United States, 59 F.3d 117, 119-20 (9th Cir.1995). The district court did not err in finding that Schulz failed to meet his burden of proving…