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GUTHRIE v. SAWYER

Nos. 91-5010, 91-5011.

970 F.2d 733 (1992)

James E. GUTHRIE; Beatrice M. Guthrie, Plaintiffs-Appellants, v. K.J. SAWYER, District Director; Gary L. Collins, Chief, Special Procedures; V. Regan, Chief, Collection Division; Karen Babcock, Internal Revenue Officer; Commissioner of the Internal Revenue Service; Internal Revenue Service, Defendants, and United States of America, Defendant-Appellee. Wayne E. WELLS; Dorothy R. Wells, Plaintiffs-Appellants, v. K.J. SAWYER, District Director; Gary L. Collins, Chief, Special Procedures; V. Regan, Chief, Collection Division; Karen Babcock, Internal Revenue Officer; Commissioner of the Internal Revenue Service; Internal Revenue Service, Defendants, and United States of America, Defendant-Appellee.

United States Court of Appeals, Tenth Circuit.

July 21, 1992.

Attorney(s) appearing for the Case

James E. Guthrie and Beatrice M. Guthrie, pro se.

Wayne E. Wells and Dorothy E. Wells, pro se.

Shirley D. Peterson, Asst. Atty. Gen., Tax Div., Dept. of Justice, Gary R. Allen, David I. Pincus, and Kimberly S. Stanley, Attys., Tax Div., Dept. of Justice, Washington, D.C., and Tony M. Graham, U.S. Atty., N.D. Okl., for defendant-appellee.

Before McKAY, Chief Judge, SEYMOUR and EBEL, Circuit Judges.

SEYMOUR, Circuit Judge.

In these consolidated cases, the pro se taxpayers appeal the district court's disposition of their suits challenging the proceedings by which the Internal Revenue Service (IRS) collected federal income taxes assessed against them. James and Beatrice Guthrie contend that (1) the tax liens filed against them and the levies on their wages are invalid because the IRS failed to exercise due diligence in mailing to them the statutorily-mandated notices...

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