MEMORANDUM **

The district court did not clearly err by granting the petition because John Schlabach (“Schlabach”) failed to rebut the government’s showing that the summons was issued in good faith. See Stewart v. United States, 511 F.3d 1251, 1254-55 (9th Cir. 2008) (taxpayer’s heavy burden to show abuse of process or lack of good faith once government makes prima facie showing summons was issued in good faith).

Schlabach’s remaining contentions are unpersuasive.

AFFIRMED.