Haye

MEMORANDUM OF DECISION AND ORDER

Simply put, the genesis of this litigation lies in the complete and utter inability of several parties to spell correctly the name “Castillo.” As will develop, one Manuel de J. Castillo took title to a parcel of real property in 1971. The deed, duly recorded, referred to him as “Cattillo.” Years later, Dr. Castillo fell into tax trouble with the federal government. The IRS duly filed its Notice of Tax Lien (Form 688) with the Los Angeles County Recorder’s office. The Notice, however, referred to Dr. Castillo as “Manual de J. Castello,” misspelling both his first and last names. Castillo subsequently transferred the property to a “friend,” who thereupon — without Castillo’s knowledge — transferred the parcel to plain tiffs. All the transactions were duly recorded. The government, on the basis of its tax lien, now wishes to sell the parcel. The plaintiffs, understandably attached to their homestead, resist this effort.

The plaintiffs filed this complaint to quiet title to real property, to cancel a federal tax lien, and seeking injunctive relief on June 22, 1978. The United States had seized the property on June 8, 1978, pursuant to its levy, and…