May a federal court exercise subject matter jurisdiction in an action to reduce to judgment an asserted estate tax lien case

QUESTIONS PRESENTED — ; 1. May a federal court exercise subject matter jurisdiction in an action to “reduce to judgment’ an asserted estate tax lien case where exhibits in the court record establish that . a. the decedent had conveyed the property sought to be solid “in satisfaction” years prior to his passing; and, b. there is no evidence in the administrative record that the estate involved met the "~**"_ federal estate tax filing threshold in effect for the year of decedent's passing? 2. May a federal court exercise such subject matter jurisdiction in said action where the administrative record establishes that a. the purported “assessment” upon which the claimed “estate tax lien” was made by an employee of the “Smal! (“Examination”) Division; rather , than. ‘ ; b. by the delegate of the Secretary of Treasury duly-appointed as an assessment officer pursuant to 26 C.F.R. § 301.6203-1?