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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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