United States v. Earl D. Sons Jessye M. Sons and Church of Christ

963 F.2d 381 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. UNITED STATES of America, Plaintiff-Appellee, v. Earl D. SONS; Jessye M. Sons; and Church of Christ, Defendants-Appellants. No. 91-55450. United States Court of Appeals, Ninth Circuit. May 15, 1992. 1 Before JAMES R. BROWNING and FARRIS, Circuit Judges, and George, ** District Judge, sitting by designation. 2 MEMORANDUM *** 3 The Sons challenge the authority of the district court to order the sale of their family home on the basis that Jessye Sons, who owned a joint tenant interest in the home, was not liable for the tax obligations giving rise to the sale. The Sons ask that Jeesye be provided with a reasonable opportunity to purchase the home in a private sale in order to protect her interest as a joint tenant. 4 When an assessment has been made and reduced to judgment, the district court has the authority to order a sale of the entire property in which a delinquent taxpayer has an interest. 26 U.S.C. §…