as for [Plaintiffs],” and “demand[] that [Government’s] counsel provide this court with the case law that forbids banks from using this form of commercial paper to create assets, and how that is denied to the private citizen.” Id. at 4. Since the Notes were not returned, Plaintiffs contend they should be deemed as accepted by the Government. Id. In additi 74, 289 (1992) (finding that an IRS Certificate of Assessment and Payment, attached to the Government’s Motion for Partial Dismissal is presumptively correct and admissible). The taxpayer bears the “burden of proving by a preponderance of the evidence that the [Government] did not assess tax in the amount stated on the Certificate.” Gov’t Resp. at 2 (citing Dallin ex. rel. Estate of Young v. United States, 62 Fed.Cl. 589, 601 (2004) (<HOLDING>), app. dismissed, 124 Fed.Appx. 660
holding that the burden is on the plaintiff holding that the party challenging a tax deed has the burden to prove its invalidity holding that even where taxpayer did not have the financial means to pay all of the taxes owed the taxpayer still willfully evaded tax obligation holding that the taxpayer has the burden to prove the governments tax assessment is incorrect holding that in a proceeding to recover taxes from a nonbankrupt taxpayer the taxpayer has the burden of proving that his taxes complied with the internal revenue code