United States v. Stacey

MEMORANDUM **

1. The evidence was sufficient for a rational jury to find that Ronald and Ele*17cia Stacey (together, the “Defendants”) had a tax due and owing. The certificates of assessment were neither challenged nor proved to be invalid. See United States v. Voorhies, 658 F.2d 710, 715 (9th Cir.1981) (recognizing certificates of assessment as adequate evidence of tax liability).

2. Whether or not Mrs. Stacey knew of the tax deficiency at the time of filing, she was on notice that a deficiency existed once the notices of deficiency were sent to her and her husband. See Roszkos v. Commissioner,…