United States v. Jiajie Chen
Opinion
Trial Court Opinion
Case 2:22-cv-02515-SVW-AS Document Filed 04/28/ Page 1 of Page ID #:
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UNITED STATES DISTRICT COURT
FOR THE CENTRAL DISTRICT OF CALIFORNIA
9 UNITED STATES OF AMERICA, No. 2:22-cv-02515-SVW-AS Petitioner,
ORDER TO SHOW CAUSE
v. JIAJIE CHEN, Respondent. 15 Upon the Petition and supporting Memorandum of Points and Authorities, and the supporting Declaration to the Petition, the Court finds that Petitioner has established its prima facie case for judicial enforcement of the subject Internal Revenue Service (“IRS” and “Service”) summons. See United States v. Powell, 379 U.S. 48, 57-58 (1964); see also Crystal v. United States, 172 F.3d 1141, 1143-1144 (9th Cir. 1999); United States v. Jose, 131 F.3d 1325, 1327 (9th Cir. 1997); Fortney v. United States, 59 F.3d 117, 119- 120 (9th Cir. 1995) (the Government’s prima facie case is typi cally made through the sworn declaration of the IRS agent who issued the summons); accord, United States v. Gilleran, 992 F.2d 232, 233 (9th Cir. 1993). THEREFORE, IT IS ORDERED that Respondent appear before…