United States of America v. Peterson, et al., No. 1:2023cv01326 - Document 14 (E.D. Cal. 2023)

Court Description: ORDER ADOPTING 11 Findings and Recommendations Regarding Petition to Enforce Internal Revenue Service Summons, signed by District Judge Jennifer L. Thurston on 12/19/2023. Respondents are ORDERED to appear at the Internal Revenue Service offices located at 2525 Capitol Street, Suite 204, Fresno, California 93721 (or by telephone pursuant to the consent of Respondents), before Revenue Agent Shannon De Voe Ramsey on January 19, 2024 at 10:00 a.m. to give testimony. (Marrujo, C)

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1 2 3 UNITED STATES DISTRICT COURT 4 EASTERN DISTRICT OF CALIFORNIA 5 UNITED STATES OF AMERICA, Case No. 1:23-cv-01326-JLT-BAM 6 Petitioner, 7 v. 8 9 JENNIFER PETERSON and STEVEN PETERSON, ORDER ADOPTING FINDINGS AND RECOMMENDATIONS REGARDING PETITION TO ENFORCE INTERNAL REVENUE SERVICE SUMMONS (Docs. 1, 11) 10 Respondents. 11 12 The United States filed a Petition to Enforce two Internal Revenue Service Summons issued to 13 Jennifer Peterson and Steven Peterson. (Doc. 1.) The summons is part of an investigation to secure 14 requested testimony, books, records, papers, and other data needed to collect the Petersons’ tax liability 15 for the years 2016 through 2020. (Id. at 1-2.) 16 The assigned magistrate judge issued an Order to Show Cause as to why those summonses 17 should not be enforced and set a show cause hearing for November 3, 2023. (Doc. 5.) A copy of that 18 order, along with the Petition, and its supporting documents was personally served on both Respondents. 19 (Docs. 6, 7.) When the matter came before the assigned magistrate judge for hearing (Doc. 8), neither 20 Respondent filed a response to the Order to Show Cause nor appeared at the hearing. (Doc. 9.) 21 Consequently, the assigned magistrate judge issued findings and recommendations, which 22 concluded that the I.R.S. summons issued to the respondents should be enforced. (Doc. 11.) The Court 23 served the findings and recommendations on the respondents and notified them that any objections were 24 to be filed within fourteen days after service. (Docs. 11, 13.) To date, the respondents have filed no 25 objections to the findings and recommendations, and the time in which to do so has passed. 26 The Court has conducted a de novo review of this case. (28 U.S.C. § 636(b)(1)(C).) Having 27 carefully reviewed the entire file, the Court finds the findings and recommendations are supported by the 28 record and proper analysis. Thus, the Court ORDERS: 1 30 1 1. The findings and recommendations issued on November 8, 2023 (Doc. 11) are ADOPTED IN FULL. 2 3 2. The I.R.S. summons issued to respondents is hereby ENFORCED. 4 3. Respondents are ORDERED to appear at the Internal Revenue Service offices located at 5 2525 Capitol Street, Suite 204, Fresno, California 93721 (or by telephone pursuant to the 6 consent of Respondents), before Revenue Agent Shannon De Voe Ramsey on January 19, 7 2024 at 10:00 a.m.1 to give testimony. 8 4. checks, records, papers, and other data demanded by the summons. 9 10 Respondents are further ORDERED to produce for examining and copying the books, 5. Failure to comply with this order may result in the issuance of sanctions. 11 12 13 IT IS SO ORDERED. Dated: December 19, 2023 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 Ms. DeVoe Ramsey or her representative may agree to a different date/time for this testimony. 2 30

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