Michael A. Zapara and Gina A. Zapara - Page 12

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          notice of sale, section 6335(f) provides a remedy.  See Anderson            
          v. United States, 44 F.3d 795, 800 (9th Cir. 1995).  The owner              
          may request the sale to take place within 60 days, and the                  
          Secretary “shall comply with such request”, unless the Secretary            
          determines (and notifies the owner within the requisite 60 days)            
          that the sale would not be in the best interests of the United              
          States.  Sec. 6335(f).  The Federal courts “have always required            
          strict compliance by the government with � 6335”.  Anderson v.              
          United States, supra at 800.                                                
               The regulations under section 6335(f) prescribe the form in            
          which the section 6335(f) request is to be made.  We have no                
          occasion here to question respondent’s ability to insist upon               
          strict adherence to those regulatory requirements in the first              
          instance when a taxpayer requests respondent to sell seized                 
          property.  But where, as in this case, respondent’s agents and              
          officers themselves appeared unaware of either the statutory or             
          regulatory requirements under section 6335(f), and received and             
          processed petitioners’ request to sell the seized property,                 
          insisting only upon conditions that lie outside the regulatory              
          requirements, and the facts do not indicate that respondent                 
          otherwise lacked the information necessary to comply with                   
          petitioners’ request, respondent cannot be heard to complain in             
          hindsight that petitioners’ request was insufficient.                       
               Respondent contends that the Appeals officer did not abuse             
          her discretion in “finding that petitioners did not make a                  




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