Liddell

MEMORANDUM *

In this consolidated appeal, Morgan Liddell and Delia Valentin (collectively “Taxpayers”) appeal a district court order enforcing against them several Internal Revenue Service (“IRS”) summonses. We affirm. Because the parties are familiar with the factual and procedural history of this case, we need not recount it here.

I

We review for clear error a district court’s decision to enforce an IRS summons. United States v. Blackman, 72 F.3d 1418, 1422 (9th Cir.1995). To enforce an IRS summons, the Service must first make a prima facie showing that the summons was issued in good faith. United States v. Powell, 379 U.S. 48, 57-58 , 85 S.Ct. 248 , 13 L.Ed.2d 112 (1964). This initial burden is “slight,” and may generally be satisfied by a sworn declaration by an IRS agent. Stewart v. United States, 511 F.3d 1251, 1254 (9th Cir.2008) (quoting Fortney v. United States, 59 F.3d 117, 120 (9th Cir.1995)). Once this low standard is met, the taxpayer faces the heavy burden of establishing that the summons was not issued in good faith, which he may only do through allegations supported by specific facts and evidence. United States v. Jose, 131 F.3d 1325, 1328 (9th Cir.1997) (en…