Ramon A. Borrero v. United States

43 F.3d 1478 74 A.F.T.R.2d 94 -7435, 95-1 USTC P 50,025 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Ramon A. BORRERO, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee. No. 94-15143. United States Court of Appeals, Ninth Circuit. Submitted Dec. 6, 1994. * Decided Dec. 9, 1994. Before: D.W. NELSON, HALL, and TROTT, Circuit Judges. 1 MEMORANDUM ** 2 Ramon A. Borrero appeals pro se the district court's summary judgment in favor of the United States in Borrero's action to quiet title under 28 U.S.C. Sec. 2410 . On appeal, Borrero contends that the district court erred by granting summary judgment because the Internal Revenue Service ("IRS") failed to: (1) serve him with notices of deficiencies for tax years 1984, 1985, and 1986; (2) provide him with notices of assessment and demands for payments with respect to the assessments; or (3) properly serve him with notices of the proposed sales of his seized assets. We have jurisdiction pursuant to 28 U.S.C.…