United States v. Sally Cobb

458 F. App'x 587

Opinion

MEMORANDUM **

Sally Dawn Cobb appeals pro se from the district court’s order granting the government’s petition to enforce summonses against her in connection with an investigation into income tax liabilities. We have jurisdiction under 28 U.S.C. § 1291. We review for clear error, Fortney v. United States, 59 F.3d 117, 119 (9th Cir.1995), and we affirm.

The district court did not commit clear error by granting the petition because Cobb failed to rebut the government’s showing that the summonses were issued in good faith. See id. at 119-20 (discuss ing the burden for rebutting the government’s showing of good faith).

Cobb’s contention that she is not subject to the Internal Revenue Code is unpersuasive. See 26 U.S.C. § 7602(a)(2) (permitting government to summons any “person”); United States v. Studley, 783 F.2d 984, 937 (9th Cir.1986) (rejecting the argument that a citizen is not subject to federal taxes).

AFFIRMED.

** This disposition is not appropriate for publication and is not precedent except as provided by 9th Cir. R. 36-3.