Whether a quiet title action requires taxpayer legal interest in property

QUESTIONS PRESENTED 1. Whether a quiet title action brought against the government pursuant to 28 U.S.C. § 2410(a) requires the taxpayer to retain a legal interest in the subject property, as the Sixth, Ninth, and Eleventh Circuits hold, or whether the attachment of a federal tax lien to the subject property is sufficient alone to abrogate the government’s sovereign immunity under that provision, as the Third and Fifth Circuits hold. 2. Whether the government may lawfully invoke its sovereign immunity to a taxpayer’s 28 U.S.C. § 2410(a) claim after luring the taxpayer into ceding his legal interest in the subject property and concluding an undisclosed side agreement with a third party to dispose of the property for a fraction of its actual worth. 3. Whether the government may selectively deplete a taxpayer’s assets by voluntarily forfeiting the fair market value realized from the sale of his home and recouping the shortfall by levying on his remaining assets. ii LIST OF PROCEEDINGS BELOW United States Court of Appeals for the Sixth Circuit Case No. 18-1728 Charles R. Hunter, v. United States of America; Sterling Mortgage and Investment Company, Decision Date: April 30, 2019 United States District Court for the Eastern District of Michigan, Southern Division Case No. 17-13494 Charles R. Hunter, Plaintiff v. United States of America, Et Al, Defendants. Decision Date: April 30, 2018