Richard A. Bay v. United States of America Arvid Sjogren

995 F.2d 230 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Richard A. BAY, Plaintiff-Appellant, v. UNITED STATES of America; Arvid Sjogren; et al., Defendants-Appellees. No. 92-35584. United States Court of Appeals, Ninth Circuit. Submitted May 25, 1993. * Decided June 2, 1993. Before: HUG, WIGGINS, and THOMPSON, Circuit Judges. 1 MEMORANDUM ** 2 Richard A. Bay appeals pro se the district court's partial summary judgment for the United States in his action to quiet title to real property seized and sold by the Internal Revenue Service (IRS) to collect income taxes Bay owed for the tax years 1979 and 1980. In its order granting in part and denying in part Bay's and the United States' motions for summary judgment, the district court held that the IRS had not complied with the notice requirements of 26 U.S.C. § 6335 in seizing and selling Bay's property, and that the sale therefore was invalid. In the portion of the order which is the subject of this appeal, the…