John Wilde, as Personal Representative for the Estate of Arthur F. Sherrell, Cecilia Sherrel v. United States

65 F.3d 177 76 A.F.T.R.2d 95 -6120 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. John WILDE, as personal representative for the estate of Arthur F. Sherrell, Cecilia Sherrel, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee. No. 93-15538. United States Court of Appeals, Ninth Circuit. Submitted Aug. 16, 1995. * Decided Aug. 22, 1995. Before: ALARCON, FERNANDEZ, and RYMER, Circuit Judges. 1 MEMORANDUM ** 2 John Wilde, as representative of the estate of taxpayer Arthur Sherrell, and Cecilia Sherrell, Arthur Sherrell's wife, (collectively "appellants") appeal pro se the district court's summary judgment on remand from this court in favor of the United States. Appellants challenge the validity of tax liens placed on Arthur Sherrell's property by the Internal Revenue Service ("IRS") for liabilities for tax years 1982 and 1983. Appellants also appeal the district court's denial of their motion for a continuance pursuant to Fed.R.Civ.P. 56(f), and the…