However, Congress specifically excluded from § 7609 petitions to quash summonses “served on the Case 2:13-cv-00623-MMD-CWH Document 4 Filed 06/11/13 Page 1 of 3 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 person with respect to whose liability the summons is issued, or any officer or employee of such person.” 26 U.S.C. § 7209(c)(2)(A). Accordingly, neither MRI nor Mr. Fujinaga can show any waiver of the United States’ sovereign immunity or otherwise assert any cause of action here.