The following excerpt is from United States v. Klingenberg, 1:14-cv-01263-LJO-BAM (E.D. Cal. 2014):
Subject matter jurisdiction is invoked under 28 U.S.C. 1340 and 1345, and is found to be proper. I.R.C. 7402(b) and 7604(a) (26 U.S.C.) authorize the government to bring the action. The Order to Show Cause shifted to Respondent the burden of rebutting any of the four requirements of United States v. Powell, 379 U.S. 48, 57-58 (1964).
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