United States v. George Parker

MEMORANDUM

George Steven Parker appeals the district court’s grant of summary judgment to the United States in its suit seeking to reduce to judgment Parker’s federal income tax liability. Representing himself on appeal, Parker claims that he introduced evidence creating a triable issue of fact respecting (1) the government’s tax assessment, (2) whether this assessment (if valid) was discharged in his personal bankruptcy, and (3) the validity of the government’s liens on his prebankruptcy property-

We review Parker’s appeal from the grant of summary judgment de novo, viewing the evidence in the light most favorable to Parker. Palmer v. Comm’r, 116 F.3d 1309 , 1311 (9th Cir.1997). Therein, we must determine whether there are any “genuine issues of material fact precluding summary judgment” in favor of the United States. Id.

I.

In a collection case brought by the United States to reduce its tax assessments to judgment, “the government bears the initial burden of proof.” Id. at 1312. The government’s Certificates of Assessments and Payments satisfied this initial burden here and created a presumption of correctness. Id. at 1311. The amounts are supported by the language of the…