The following excerpt is from U.S. v. Trohimovich, 905 F.2d 1541 (9th Cir. 1990):
2 While decreeing a judicial sale and appointing a receiver is discretionary, case law supports the government's contention that the discretion to refuse to order a sale is limited. "We can think of virtually no circumstances, for example, in which it would be permissible to refuse to authorize a sale simply to protect the interests of the delinquent taxpayer himself or herself." United States v. Rodgers, 461 U.S. 677, 709 (1983).
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