must be strictly construed. See Reece v. Scoggins, 506 F.2d 967, 971-72 (5th Cir.1975). It is clear that the IRS sold the property in Harris County, not Galveston County, where the property was located. The sale also occurred nearly nine months after the IRS had given initial notice of sale, which was well beyond the limit of 40 days, plus a possible one-month adjournment, allowed under section 6335. In addition, the property was not released to the Johnstons following the postponement of the first sale. Although these actions may not have complied with the Internal Revenue Code’s procedures for selling the property, the law is well settled that noncompliance with section 6335 causes the sale to be voidable at the option of the taxpayer and not void. See, e.g., Reece, 506 F.2d at 970 (<HOLDING>); Johnson v. Gartlan, 470 F.2d 1104, 1106 (4th
holding in action for breach of contract caused by wrongful foreclosure and sale of shares of stock plaintiff was entitled to recover the fair market value of the stock at the time of its sale holding that failure to comply with rule requiring notice of sheriffs sale requires voiding of sale holding in the analogous context of choiceoflaw in relation to the sale of personal property that compensation for arranging the sale is assessed apart from underlying sale holding that where property subject to the irss timely filed lien is sold during a nonjudicial sale and the irs is not given notice of the sale the sale of the property is made subject to and without disturbing the lien holding that failure of irs to provide statutory notice of sale caused sale to be voidable ab initio