William Saenger Marianne Saenger v. United States of America Dennis B. Sullivan

996 F.2d 1227 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. William SAENGER; Marianne Saenger, Plaintiffs-Appellants, v. UNITED STATES of America; Dennis B. Sullivan, et al., Defendants-Appellees. No. 92-35339. United States Court of Appeals, Ninth Circuit. Submitted June 8, 1993. * Decided June 18, 1993. Before CANBY, FERNANDEZ and T.G. NELSON, Circuit Judges. 1 MEMORANDUM ** 2 Taxpayers William and Marianne Saenger appeal pro se from the district court's summary judgment for the United States in their 28 U.S.C. § 2410 quiet title action. We have jurisdiction pursuant to 28 U.S.C. § 1291 , and we affirm. 3 Section 2410 of the Internal Revenue Code states in pertinent part: "the United States may be named a party in any civil action or suit in any district court ... to quiet title to ... real or personal property on which the United States has or claims a mortgage or other lien." 28 U.S.C. § 2410 . We have interpreted section 2410 as a limited waiver of…