United States v. Shaun Allahyari

FOR PUBLICATION

UNITED STATES COURT OF APPEALS

FOR THE NINTH CIRCUIT

UNITED STATES OF AMERICA, No. 22-35422

Plaintiff - Appellee, D.C. No. 2:17- cv-00668-TSZ v.

SHAUN ALLAHYARI, OPINION

Defendant - Appellant, and

KOMRON M. ALLAHYARI,

Defendant.

Appeal from the United States District Court for the Western District of Washington Thomas S. Zilly, District Judge, Presiding

Argued and Submitted September 12, 2023 Seattle, Washington

Filed April 17, 2024

Before: Michael D. Hawkins, Ryan D. Nelson, and Daniel P. Collins, Circuit Judges.

Opinion by Judge Collins SUMMARY *

Tax

The panel dismissed an appeal for lack of jurisdiction, in an action by the government to reduce federal tax liens to judgment and foreclose on real property, because there was no final decision to appeal. The order that taxpayer sought to appeal found that the government was entitled to foreclose on the tax liens, and to the sale of certain real property. However, the order was not final because the district court did not have sufficient information to enter an order for judicial sale. Instead, the district court ordered the…