district court dismissed the petition for lack of subject matter jurisdiction, relying on two, almost factually-identical circuit precedents. See Deal v. United States, 759 F.2d 442 (5th Cir.1985); Masat v. United States, 745 F.2d 985 (5th Cir.1984). Deal and Masat concerned taxpayer challenges to IRS third-party summonses. Both affirmed dismissals for lack of subject matter jurisdiction, reasoning that the Internal Revenue Code vests jurisdiction over such challenges in the district court where the third-party resides. See 26 U.S.C. § 7609(h)(1) (“The United States district court for the district within which the person to be summoned resides or is found shall have jurisdiction to hear and determine any proceeding brought under subsection (b)(2), (f), or (g).”); Deal, 759 F.2d at 444 (<HOLDING>); Masat, 745 F.2d at 986, 988. The Williamses
holding that where the issue of sanctions was not before the court of appeals when the appeal was filed the district court retained jurisdiction holding the rule against taxpayer standing applies both to federal taxpayers and state taxpayers challenging state tax or spending decisions simply by virtue of their status as state taxpayers holding that the plaintiff was precluded from raising the issue for the first time on appeal holding that masat precluded the taxpayers appeal and that jurisdiction was exclusively in the district where the thirdparty record keepers reside holding that an appeal by taxpayers in a lawsuit seeking to enjoin the government from collecting income tax deficiencies was mooted because the taxpayers had paid the deficiencies pending the appeal