Case Explained: USA V. HOWE, ET AL.

Court: United States Court of Appeals for the Ninth Circuit Filed: 2026-06-23 Docket: 2:19-cv-00421-DCN The ninth-circuit affirmed the district court’s order of sale and summary judgment in favor of the United States regarding income tax assessments. The court held that Ebenezer K. Howe IV failed to raise a genuine dispute of material fact as to his liability for the assessments, noting that once the government introduces evidence of the tax assessment, the burden shifts to the taxpayer to prove non-liability. Additionally, the court found no abuse of discretion in the district court’s denial of Howe’s motion to reopen discovery, ruling that he failed to demonstrate diligent pursuit of prior discovery opportunities or that additional discovery would have precluded summary judgment. The court also rejected unsupported contentions regarding unclean hands and declined to consider issues not specifically argued in the opening brief. As a result, all pending motions are denied and the district court’s orders remain in effect. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.