Mari Fleetwood, Plaintiff-appellant, v. United States of America; Debra Ahn, I.r.s. Agent; Paulbeene, I.r.s. Dist. Director, Defendants-appellees, 76 F.3d 386 (9th Cir. 1996)

MEMORANDUM^** 

Mari Fleetwood appeals pro se the district court's dismissal as untimely of her motion to quash six third party recordkeeper summonses issued by the Internal Revenue Service. We have jurisdiction pursuant to 28 U.S.C. § 1291, and we affirm.

When an IRS summons is issued to a third party recordkeeper, the taxpayer, as a person "entitled to notice of a summons" under 26 U.S.C. § 7609(a), has twenty days from the date of notice to bring a proceeding to quash the summons. See 26 U.S.C. § 7609(b) (2) (A); Ponsford v. United States, 771 F.2d 1305, 1309 (9th Cir. 1985). The twenty-day period is jurisdictional. See Ponsford, 771 F.2d at 1309.

We affirm the district court's dismissal as untimely of Fleetwood's petition because she did not move to quash the six summonses within the twenty-day period.

AFFIRMED.