Legal Opinion
Chen Chi Wang and Wayne Chen v. United States
Court of Appeals for the Ninth Circuit
Decided April 9, 1985No. 83-2577PublishedCited by 22 opinions
1Opinion of the Court
DUNIWAY, Circuit Judge:
Wang and Chen appeal from the district court order dismissing their petition to quash an Internal Revenue Service (IRS) summons issued to Whitfield Management Services. They argue (1) that Whitfield is a “third party recordkeeper” under 26 U.S.C. § 7609 and the summons was improper because they were not given notice, and (2) that as a “target” of a third party subpoena, they are independently entitled to intervene under general law principles. In addition, (3) they challenge the district court’s denial of a discovery request. We affirm on each point.
I. Background.
In…
2Cases cited16 opinions
- Robert G. Vaughn v. Bernard Rosen, Executive Director, United States Civil Service CommissionCourt of Appeals for the D.C. Circuit · 1973
- Burnet v. HarmelSupreme Court of the United States · 1932
- Donaldson v. United StatesSupreme Court of the United States · 1971
- United States v. CorrellSupreme Court of the United States · 1967
- Reisman v. CaplinSupreme Court of the United States · 1964
11 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- Moore v. California State Board of AccountancyCalifornia Supreme Court · 1992
- John Crystal Victoria Crystal John Crystal Pools, Inc. v. United StatesCourt of Appeals for the Ninth Circuit · 1999
- Ponsford v. United StatesCourt of Appeals for the Ninth Circuit · 1985
- United States v. AbrahamsCourt of Appeals for the Ninth Circuit · 1990
- Anesthesia Service Medical Group, Inc. v. CommissionerUnited States Tax Court · 1985
17 more not listed; retrieve them via the Exa API.