Vincent C. Wiley v. United States of America Citizens Federal Mortgage Corporation State of Ohio Franklin County Treasurer and Houng Thai

MILBURN, Circuit Judge.

Plaintiff Wiley appeals the district court’s denial of his motion for summary judgment and the grant of summary judgment to defendant United' States of America. On appeal, the issue is whether there is a genuine issue of material fact as to whether the Internal Revenue Service mailed the statutorily required notice of deficiency to plaintiff. For the reasons that follow, we affirm the denial of summary judgment to the plaintiff and reverse the grant of summary judgment to the defendant.

I

On August 14, 1991, plaintiff Vincent C. Wiley filed this action to quiet title to…