USA v. Patricia Rivers, No. 22-1742 (7th Cir. 2023)
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NONPRECEDENTIAL DISPOSITION To be cited only in accordance with FED. R. APP. P. 32.1 United States Court of Appeals For the Seventh Circuit Chicago, Illinois 60604 Submitted April 28, 2023* Decided April 28, 2023 Before MICHAEL B. BRENNAN, Circuit Judge MICHAEL Y. SCUDDER, Circuit Judge AMY J. ST. EVE, Circuit Judge No. 22-1742 UNITED STATES OF AMERICA, Plaintiff-Appellee, Appeal from the United States District Court for the Northern District of Illinois, Eastern Division. v. No. 1:20-CV-03313 PATRICIA RIVERS, Defendant-Appellant. Edmond E. Chang, Judge. ORDER Patricia Rivers, a tax preparer who operated her own tax-preparation company, repeatedly drew up fraudulent federal income-tax returns for customers. The We have agreed to decide the case without oral argument because the briefs and record adequately present the facts and legal arguments, and oral argument would not significantly aid the court. FED. R. APP. P. 34(a)(2)(C). * No. 22-1742 Page 2 government sued Rivers and her company for engaging in conduct subject to penalty under the Internal Revenue Code, 26 U.S.C. §§ 6694 and 6695—for example, fabricating customers’ charitable donations, unreimbursed employee expenses, and business losses. Their attorney soon moved to withdraw. After holding an ex-parte hearing, the court granted the attorney’s motion. The court then gave Rivers and the company two weeks to obtain new counsel. Neither Rivers nor the company retained counsel, and the court entered a default against both. The court later granted the government’s motion for summary judgment and a permanent injunction barring Rivers and her company from engaging in tax-preparation activities. On appeal, Rivers generally contests the district court’s order, but she barely develops any challenge to the court’s ruling. See FED. R. APP. P. 28(a)(8)(A) (the argument must contain “appellant’s contentions and the reasons for them, with citations to the authorities and parts of the record on which the appellant relies”). To the extent Rivers develops any argument, she suggests that she should have been afforded an opportunity to obtain counsel to represent her company. But the court gave her and the company two weeks to do so, and she does not explain why that invitation was insufficient. Nor did she ask the court for additional time to find counsel. She also suggests that the court should have held a hearing before granting defense counsel’s motion to withdraw, but the court did just that. We have reviewed the record and AFFIRM for substantially the reasons stated by the district court.
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