Irvin L. Adkins v. United States of America Commissioner of Internal Revenue Service Shawn Chang

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NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Irvin L. ADKINS, Plaintiff-Appellant, v. UNITED STATES of America; Commissioner of Internal Revenue Service; Shawn Chang, Defendants-Appellees. No. 91-55223. 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 Irvin L. Adkins appeals pro se the district court's dismissal of his action seeking injunctive and declaratory relief from the Internal Revenue Service's ("IRS") levy, seizure, and sale of his real property for failure to file income tax returns or to pay his tax liabilities for tax years 1983 through 1986. Adkins also sought to quiet title against the purchaser of the property, Shawn Chang. The district court found that it lacked subject matter jurisdiction to hear Adkins's claim against the IRS and that Adkins's claim against Chang must be dismissed under Fed.R.Civ.P. 12(b)(6). We have…