Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 DEAN STEEVES, Case No. 26-cv-0568-BAS-VET 11 Plaintiff, ORDER: 12 13 v. (1) ADOPTING REPORT AND RECOMMENDATION 14 UNITED STATES OF AMERICA, (ECF No. 9);

Defendant. 15 (2) GRANTING DEFENDANT’S MOTION 16 TO ENFORCE THE IRS SUMMONS 17 (ECF No. 4); AND 18 (3) DENYING PLAINTIFF’S 19 MOTION TO QUASH THE IRS SUMMONS 20 (ECF NO. 1)

21 22 23 Presently before the Court are two motions. One is Plaintiff Dean Steeves’ 24 motion to quash an Internal Revenue Service (“IRS”) summons brought by 25 Defendant United States of America. (ECF No. 1.) The other is Defendant’s motion 26 to enforce the IRS summons and summarily deny Plaintiff’s motion to quash. (ECF 27 No. 4.) 1 Under General Order 620, Matters Assigned to the Chief Judge (S.D. Cal. Nov. 2 16, 2012), the Chief District Judge is responsible for adjudicating the motions. 3 Further, the Chief Judge may refer the matter “to a Magistrate Judge as authorized 4 by 28 U.S.C. § 636(b) and (c), and Local Civil Rule 72.” Id. Accordingly, on January 5 28, 2026, the undersigned referred the motions to the Honorable Valerie E. Torres. 6 (ECF Nos. 1, 3.) 7 On July 27, 2026, Judge Torres issued a Report and Recommendation 8 (“R&R”) recommending that this Court dismiss Plaintiff’s petition to quash the IRS 9 summons and grant Defendant’s motion to enforce the IRS summons. (ECF No. 9.) 10 The time for filing objections has expired. (R&R 13:23–26, ECF No. 9.) Hence, the 11 R&R is ripe for consideration. 12 I. ANALYSIS 13 The court reviews de novo those portions of the R&R to which objections are 14 made. 28 U.S.C. § 636(b)(1). It may “accept, reject, or modify, in whole or in part, 15 the findings or recommendations made by the magistrate judge.” Id. But “[t]he statute 16 makes it clear that the district judge must review the magistrate judge’s findings and 17 recommendations de novo if objection is made, but not otherwise.” United States v. 18 Reyna-Tapia, 328 F.3d 1114, 1121 (9th Cir. 2003) (en banc); see also Schmidt v. 19 Johnstone, 263 F. Supp. 2d 1219, 1226 (D. Ariz. 2003) (concluding that where no 20 objections were filed, the district court had no obligation to review the magistrate 21 judge’s report). “Neither the Constitution nor the statute requires a district judge to 22 review, de novo, findings and recommendations that the parties themselves accept as 23 correct.” Reyna-Tapia, 328 F.3d at 1121. This rule of law is well-established within 24 the Ninth Circuit and this district. See Wang v. Masaitis, 416 F.3d 992, 1000 n.13 25 (9th Cir. 2005) (“Of course, de novo review of a R & R is only required when an 26 objection is made to the R & R.”); Nelson v. Giurbino, 395 F. Supp. 2d 946, 949 27 (S.D. Cal. 2005) (adopting R&R in its entirety without review because neither party 1 In this case, the deadline for filing objections was August 10, 2026. (R&R 2 || 13:23-26.) However, no objections have been filed, and no party has requested 3 || additional time to do so. Consequently, the Court may adopt the R&R on that basis 4 |{alone. See Reyna-Tapia, 328 F.3d at 1121. 5 Nonetheless, having conducted a review of the R&R, the Court concludes that 6 ||Judge Torres’ reasoning is sound and correct in recommending that this Court 7 || dismiss Plaintiffs petition to quash the IRS summons and grant Defendant’s motion 8 to enforce the IRS summons. 9 ||. CONCLUSION 10 In light of the foregoing, the Court APPROVES and ADOPTS IN ITS 11 ENTIRETY the R&R. (ECF No. 9.) The Court GRANTS Defendant’s motion to 12 ||enforce the IRS summons and deny the petition to quash. (ECF No. 4.) The Court 13 || DENIES Plaintiff's motion to quash the IRS summons. (ECF No. 1.) 14 The Clerk of Court shall close this case. 15 IT IS SO ORDERED. 16 17 || DATED: August 12, 2026 yatta Bahar □□ 18 H n. Cynthia Bashant, Chief Judge United States District Court 19 20 21 22 23 24 25 26 27 28