Atao Healy John Patrick Healy, Plaintiffs-Counter-Claim-Defendants-Appellant v. United States of America, Defendant-Counter-Claimant-Appellee

977 F.2d 589 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Atao HEALY; John Patrick Healy, Plaintiffs-counter-claim-Defendants-Appellant, v. UNITED STATES of America, Defendant-counter-claimant-Appellee. No. 91-55656. United States Court of Appeals, Ninth Circuit. Submitted Oct. 13, 1992. * Decided Oct. 21, 1992. Before BEEZER, CYNTHIA HOLCOMB HALL and WIGGINS, Circuit Judges. 1 MEMORANDUM ** 2 John P. Healy and Atao Healy appeal pro se the district court's order dismissing their quiet title action under 28 U.S.C. § 2410 and granting summary judgment to the United States in its counterclaim seeking to reduce to judgment John P. Healy's federal income tax liabilities for tax years 1980 and 1981, and to foreclose federal tax liens against his interest in the property to which the Healys sought to quiet title. We have jurisdiction pursuant to 28 U.S.C. § 1291 and affirm. II Merits A. United States' Counterclaim 3 The Healys contend that the district court lacked…