Unpublished Disposition, 895 F.2d 1419 (9th Cir. 1990)

MEMORANDUM^** 

Marsha and Clifford Wheeler appeal pro se from the district court's order enforcing four Internal Revenue Service summonses. We affirm.

The Wheelers raise several frivolous arguments in support of their contentions that the IRS lacks authority to issue summonses and the district courts are without jurisdiction to enforce them. The IRS has such authority, 26 U.S.C. § 7602(a) (2); United States v. Euge, 444 U.S. 707, 710 (1980), and the district courts have the jurisdiction. 26 U.S.C. §§ 7402(b), 7604(a); United States v. Author Servs., 804 F.2d 1520, 1525 (CA9 1986), amended, 811 F.2d 1264 (1987). The appellants are "taxpayers" and "persons" within the meaning and intent of 26 U.S.C. § 7203, see United States v. Studley, 783 F.2d 934, 937 (CA9 1986), and were accorded all of the process to which they were due under FRCivP 81(a) (3). See Chen Chi Wang v. United States, 757 F.2d 1000, 1004 (CA9 1985); United States v. Church of Scientology, 520 F.2d 818, 821 (CA9 1975).

Because of the patently frivolous nature of this appeal, we grant the appellee's request for sanctions and award judgment for attorney's fees in the sum of $1,500 as well as double costs of this appeal. See 28 U.S.C. § 1912; FRAP 38; Grimes v. C.I.R., 806 F.2d 1451, 1454 (CA9 1986) (per curiam).

AFFIRMED.