I can't think of a less sympathetic non-criminal case than this one.
The Cheungs get indicted for conspiracy to defraud the United States and tax fraud. They lived in Seattle (and are U.S. citizens) but make haste to China, which has no extradition treaty with the United States.
From Hong Kong, they "denounce" the United States, and the IRS ultimately issues them a tax deficiency notice for several million dollars related to their fraud. They then hire a high-priced attorney to file a FOIA request seeking all sorts of information about their tax situation, which the IRS (understandably) refuses to turn over -- at least absent the Cheungs coming to the U.S.
The district court dismisses the lawsuit. The Cheungs then hire another high-priced firm (K&L Gates) to prosecute an appeal with the Ninth Circuit.
They draw a relatively good panel: Stephen Reinhardt, Willie Fletcher and Johnnie Rawlinson. But even that crowd isn't buying it. Affirmed.
Can't say I disagree. In the slightest.
P.S. - The attorney who filed the lawsuit is William P. Shannahan. A name that took me back 25 years or so to another William Shanahan I once knew -- someone who (unfortunately) had eight minutes of fame on YouTube for "mooning" individuals during a college debate dispute. Resulting in the loss of his job and, undoubtedly, much personal trauma. Which I always thought was too bad. Because the guy was -- and presumably remains -- a quality guy. One with strong feelings, as well as many unique takes on the universe. But a quality person regardless.
Unlike, I think, the Cheungs.
