John E. Codner v. United States

BALDOCK, Circuit Judge.

To determine whether petitioner-appellant John E. Codner had violated any Internal Revenue laws, the Internal Revenue Service issued twelve administrative summonses to various third parties requesting financial information regarding Codner. Codner timely filed a petition to quash the summonses on various grounds. IRS answered and filed a petition to enforce six of the summonses issued to parties residing within the District of Utah.

The district court determined that it lacked jurisdiction over the petition to quash the summonses issued to the five parties who did not…