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GOODWIN v. U.S.

No. 90-15192.

935 F.2d 1061 (1991)

Orville R. GOODWIN, Plaintiff-Appellant, v. UNITED STATES of America; Calvin E. Esselstrom; Joseph Phillips, Defendants-Appellees.

United States Court of Appeals, Ninth Circuit.

Decided June 11, 1991.

Attorney(s) appearing for the Case

David M. Kirsch, San Jose, Cal., for plaintiff-appellant.

Steven W. Parks and Kenneth L. Greene, U.S. Dept. of Justice, Tax Div., Washington, D.C., for defendants-appellees.

Before CHAMBERS, BEEZER and NOONAN, Circuit Judges.

BEEZER, Circuit Judge:

Orville R. Goodwin appeals the district court's summary judgment order which upheld the government's seizure and sale of his property for delinquent payroll taxes. Goodwin contends that the seizure and sale should be set aside because the government did not literally comply with the notice requirements of 26 U.S.C. § 6335. He also contends that the district court erred by ruling that the statute of limitations had

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