U.S. Appellate Court Affirms Subpoena in Support of Mexico’s TIEA Request

On April 22, 2013, the U.S. Court of Appeals for the 10^th Circuit, in a unanimous opinion, affirmed the district court’s order denying the motion of Salomon Juan Marcos Villarreal’s to quash a subpoena issued by the Internal Revenue Service (IRS) to the American National Bank and his request for an evidentiary hearing, and granting summary judgment for the U.S. government on its motion to enforce.[1]