The following excerpt is from Jones v. U.S., 60 F.3d 584 (9th Cir. 1995):
In an action to collect a tax, the government bears the initial burden of proof. Oliver v. United States, 921 F.2d 916, 919 (9th Cir.1990). The assessment of tax ordinarily establishes the government's prima facie case, so it becomes incumbent on the taxpayer to establish an issue of fact. Id.
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