Espinosa

MEMORANDUM *

Laura Loveland Espinosa (“Mrs.Espinosa”) petitions for review from the United *826 States Tax Court’s decision, issued after a trial, holding her liable as a transferee under I.R.C. § 6901 for a portion of the unpaid income taxes and penalties attributable to her husband, Frederick Espinosa (“Mr.Espinosa”). Mrs. Espinosa disputes the Government’s determination of Mr. Espinosa’s tax liability, and argues that the Tax Court erred by finding that the Government sustained its burden of establishing Mr. Espinosa’s insolvency at the time of the transfer. We have jurisdiction pursuant to I.R.C. § 7482, and we affirm.

Decisions of the Tax Court are reviewed under the same standards as civil bench trials conducted in the district court. Conclusions of law are reviewed de novo, while factual findings are subject to clearly erroneous review. Custom Chrome, Inc. v. Comm’r, 217 F.3d 1117, 1121 (9th Cir. 2000).

Mrs. Espinosa contends that she is not hable as a transferee because a notice defect invalidated the assessment of taxes owed by Mr. Espinosa. Because the deficiency notices the IRS mailed in 1989 were not sent to Mr. Espinosa’s last known address, she argues, there is no…