Dickey v. United States

991 F.2d 803 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. George DICKEY, Plaintiff-Appellant, v. UNITED STATES of America; Commissioner of Internal Revenue Service; United States Department of the Treasury, Revenue Officers, K. Lentine; V. Lodewyk, Defendants-Appellees. No. 92-55706. United States Court of Appeals, Ninth Circuit. Submitted April 7, 1993. * Decided April 15, 1993. Before BROWNING, KOZINSKI and RYMER, Circuit Judges. 1 MEMORANDUM ** 2 George Dickey appeals pro se the district court's dismissal of Dickey's action against the Commissioner of Internal Revenue and two Internal Revenue Service ("IRS") agents for lack of jurisdiction. Dickey alleged that the IRS illegally seized his property in satisfaction of his unpaid taxes without first issuing him the required notices. The district court dismissed Dickey's action because Dickey failed to pay the tax in issue prior to bringing his claim in district court. We have jurisdiction pursuant to 28 U.S.C. §…