Asiru

MEMORANDUM **

Jo-Ann and Dolapo Asiru (“Asirus” or “taxpayers” or, individually, “Jo-Ann” or *586 “Dolapo”) appeal the District Court’s decision reducing their federal income tax assessments to judgment and ordering the foreclosure of federal tax liens filed against Jo-Ann’s real property. Asirus contend that the assessed taxes were too high and that the District Court erred in excluding their expert witness and amended tax returns. We affirm.

DISCUSSION

I. The District Court did not err in reducing to judgment the federal tax assessments.

A. The 1990 Tax Assessment

Asirus note that the Certificate of Assessment for tax year 1990 shows a balance of zero because the ten-year statute of limitations under 26 U.S.C. § 6502 (a)(1) expired, causing the collectable amount of $37,645.72 to be zeroed out.

Although the Certificate of Assessment does show zero debt, there are two problems with Asirus’ argument. First, they failed to raise the claim below. Second, the document is inaccurate because the ten-year statute of limitations did not in fact run before the United States filed suit to collect.

The Ninth Circuit “will not ... review an issue not raised below unless necessary to…