Merlin J. Harris Margaret R. Harris v. United States of America Internal Revenue Service San Juan Unified School District
Opinion
Opinion
961 F.2d 216 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Merlin J. HARRIS; Margaret R. Harris, Plaintiffs-Appellants, v. UNITED STATES of America; Internal Revenue Service; San Juan Unified School District, Defendants-Appellees. No. 91-15312. United States Court of Appeals, Ninth Circuit. Submitted April 20, 1992. * Decided April 24, 1992. Before FARRIS, O'SCANNLAIN and TROTT, Circuit Judges. 1 MEMORANDUM ** 2 Merlin J. Harris and Margaret R. Harris appeal pro se the district court's order dismissing their action for injunctive relief and granting summary judgment in their quiet title action under 28 U.S.C. § 2410 . The Harrises contend that the lien and levy on their property are void because the Internal Revenue Service ("IRS") failed to follow its regulations for assessing and collecting tax deficiencies. We have jurisdiction pursuant to 28 U.S.C. § 1291 . We review de novo, Kruso v. International Tel. & Tel. Corp., 872 F.2d 1416 , 1421 (9th Cir.1989),…