Hixson

This cause having come before the Court for trial, and evidence having been submitted by all parties; and it appearing to the Court:

(a) that defendant United States of America, as Sovereign, has never consented to be sued in this or any court for a claim to declaratory judgment such as is presented in the first cause of action asserted in plaintiff’s complaint in this case [see: 28 U.S.C.A. § 2201 ; Mayer v. Wright, 9 Cir., 1958, 251 F.2d 178 ];

(b) that defendant United States of America has an unsatisfied lien for Federal income taxes against the real property as to which the plaintiff seeks a decree quieting title in the second cause of action asserted in the complaint, and the plaintiff does not make any offer to do equity as to the United States by offering to discharge such lien;

(c) that the record does not disclose diversity of citizenship between plaintiff and defendant William Carter Hixson [ 28 U.S.C.A. § 1332 ; Indianapolis v. Chase National Bank, 1941, 314 U.S. 63, 69-70, 76-77 , 62 S.Ct. 15 , 86 L.Ed. 47 ; Parker v. Overman, 1855, 18 How. 137 , 59 U.S. 137, 141 , 15 L.Ed. 318 ; Mullen v. Torrance, 1824, 9 Wheat. 537 , 22 U.S. 537, 538 , 6 L.Ed. 154 ; Molnar v.…