Kenneth J. Masat v. United States of America and Robert Solorio, Jr., Agent for the Internal Revenue Service

ALVIN B. RUBIN, Circuit Judge:

When the Internal Revenue Service issues a summons for records pertaining to a taxpayer directed to a third person at the place where that person resides, the district court for the district in which that person resides is the court with jurisdiction to entertain an action by the taxpayer seeking to quash that summons. We, therefore, affirm the dismissal by the court of the district in which a taxpayer resides of a petition to quash an administrative summons sought from a recordkeeper which had its principal place of business in another judicial district.

Kenneth…