United States of America and Ichiro Hirose, Revenue Officer of the Internal Revenue Service v. Anne M. Doyle

CLARK, Chief Judge:

The appellees, United States of America and Ichiro Hirose, Revenue Officer of the Internal Revenue Service, conditionally move this court to remand this proceeding to the United States District Court for the Southern District of Texas to permit appel-lees to move that court to dismiss the petition to enforce the Internal Revenue Service summons on the grounds that the information sought has been obtained from third-party sources. The condition expressed in said motion is that this court determine it has jurisdiction of the appeal in this case.

The jurisdictional issue turns…