Stewart v. United States

O’SCANNLAIN, Circuit Judge:

We are called upon to determine whether a person who is not identified in an Internal Revenue Service administrative summons issued to a third party has standing to file a petition to quash.

I

Sometime in 2005, the Internal Revenue Service (“IRS”) commenced an investigation of Morse Stewart’s income tax liabilities for the tax years 1998 through 2003. In furtherance of that investigation, Revenue Agent Carla J. Oyala issued administrative summonses to fifteen banks and mortgage companies seeking information regarding Morse’s financial accounts and transactions.…