United States of America v. Patricia Rivers

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,
v.
PATRICIA RIVERS,
Defendant-Appellant.
Appeal from the United States District
Court for the Northern District of Illinois,
Eastern Division.
No. 1:20-CV-03313
Edmond E. Chang,
Judge.
O R D E R
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. A PP. P. 34(a)(2)(C).
NONPRECEDENTIAL DISPOSITION
To be cited only in accordance with FED. R. A PP. P. 32.1

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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. A PP. 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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