
    UNITED STATES of America, Plaintiff-Appellee, v. Sally Dawn COBB, Defendant-Appellant.
    No. 08-56479.
    United States Court of Appeals, Ninth Circuit.
    Submitted Oct. 25, 2011.
    
    Filed Nov. 1, 2011.
    Ivan Clay Dale, Thomas J. Clark, Supervisory, Robert William Metzler, Supervisory, U.S. Department of Justice, Washington, DC, Carol M. Lee, Assistant U.S. Attorney, Raven M. Norris, Assistant U.S. Attorney, Office of the U.S. Attorney, San Diego, CA, for Plaintiff-Appellee.
    Sally Dawn Cobb, Valley Center, CA, pro se.
    Before: TROTT, GOULD, and RAWLINSON, Circuit Judges.
    
      
       The panel unanimously concludes this case is suitable for decision without oral argument. See Fed. R.App. P. 34(a)(2).
    
   MEMORANDUM

Sally Dawn Cobb appeals pro se from the district court’s order granting the government’s petition to enforce summonses against her in connection with an investigation into income tax liabilities. We have jurisdiction under 28 U.S.C. § 1291. We review for clear error, Fortney v. United States, 59 F.3d 117, 119 (9th Cir.1995), and we affirm.

The district court did not commit clear error by granting the petition because Cobb failed to rebut the government’s showing that the summonses were issued in good faith. See id. at 119-20 (discussing the burden for rebutting the government’s showing of good faith).

Cobb’s contention that she is not subject to the Internal Revenue Code is unpersuasive. See 26 U.S.C. § 7602(a)(2) (permitting government to summons any “person”); United States v. Studley, 783 F.2d 984, 937 (9th Cir.1986) (rejecting the argument that a citizen is not subject to federal taxes).

AFFIRMED. 
      
       This disposition is not appropriate for publication and is not precedent except as provided by 9th Cir. R. 36-3.
     