Ross P. Upton v. Internal Revenue Service and Gloria A. Hassinger, United States of America, Movant-Appellee

Ross P. Upton appeals pro se from the judgment of the United States District Court for the District of Connecticut (Burns, J.) dismissing, for lack of subject matter jurisdiction, Upton’s petition to quash an Internal Revenue Service (“IRS”) administrative summons. For the reasons that follow, we affirm.

BACKGROUND

In the course of investigating petitioner Ross Upton’s federal tax liability, the IRS issued an administrative summons to his son, James Upton: Specifically, the IRS summons requested James Upton to provide the following:

[w]ith respect to payments made by [James Upton] and/or anyone…