U.S. v. Antiques Limited Partnership

Dist. Ct. did not err in granting govt. motion for appointment of receiver for purpose of managing and liquidating taxpayer’s interests in certain partnerships and other property, where Dist. Ct. had previously found that govt.’s tax assessments and tax liens were valid. Ct. rejected taxpayer’s claim that his interests in certain limited partnerships were not subject to instant liens, where court found that liens only attached to taxpayer’s ownership interests in said partnerships. Moreover, although Dist. Ct. authorized sale of any assets held by said partnerships, said order was not improper, where taxpayer was sole owner of said partnerships. However, Ct. of Appeals lacked jurisdiction to consider taxpayer’s appeal of subsequent orders approving sale of individual pieces property since said orders were interlocutory in nature and not appealable to due fact that collection process on other pieces of property had not yet been completed.