Mayeron

MEMORANDUM ***

Taxpayer Dennis Mayeron appeals pro se from the district court’s summary judgment in favor of Defendants in Mayeron’s quiet title action arising from the Internal Revenue Service’s (“IRS”) seizure of his real property and sale to Auguste Roberts to satisfy Mayeron’s federal tax liability. We have jurisdiction under 28 U.S.C. § 1291 . We review de novo the existence of subject matter jurisdiction and for clear error factual findings relevant to this determination. See United States v. Peninsula Communications, Inc., 287 F.3d 832, 836 (9th Cir.2002). We review de novo a district court’s decision on cross motions for summary judgment. See Arakaki v. Hawaii, 314 F.3d 1091, 1094 (9th Cir. 2002). We affirm.

Mayeron’s contention that the government should be dismissed is not persuasive because the government asserts a sufficient interest in the property at the time Mayeron commenced this lawsuit and the record does not indicate otherwise. See 28 U.S.C. § 2410 ; Hansen v. United States, 7 F.3d 137 , 138 n. 1 (9th Cir.1993) (per curiam) (declining to reach whether the government waived sovereign immunity under section 2410 but noting that the “record does not contain any…