Jade Trading, LLC v. United States

ORDER AND MEMORANDUM OPINION DENYING BDO SEIDMAN, LLP’S MOTION TO AMEND OPINION TO CERTIFY FOR INTERLOCUTORY APPEAL

WILLIAMS, Judge.

On May 9, 2005, BDO Seidman, LLP, (BDO) a nonparty, filed a motion to certify an interlocutory appeal of this Court’s Order denying BDO’s motion to quash a subpoena served by Defendant seeking taxpayer information of BDO’s nonparty clients.1 Because BDO has not established that the issues presented meet the strict criteria for certification of an interlocutory appeal, BDO’s motion is denied.

Background 2

Plaintiffs bring this action under Section 6226 of the…