John A. And Mary Sue Garcia v. United States

GODBOLD, Circuit Judge:

This appeal is from a judgment of the District Court reducing to judgment assessments of income tax liabilities, penalties and interest and foreclosing tax liens on real property of the taxpayers located in Texas. The validity of the assessments is not contested on this appeal, other than on constitutional grounds discussed below.

The taxpayers, John A. and Mary Sue Garcia, claim that they were unconstitutionally deprived of counsel before the District Court and before this Court. We do not reach the question whether there ever may be a constitutional right to appointive…