What is the test for jurisdiction to bring an action in the form of an Order to Show Cause?
MultiRegion, United States of America
The following excerpt is from United States v. Pappace, 1:17-CV-00406-DAD-BAM (E.D. Cal. 2017):
Subject matter jurisdiction is invoked under 28 U.S.C. 1340 and 1345, and is found to be proper. Internal Revenue Code 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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