Sohn

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 CAROLYNE Y. SOHN, et al., Case No. 22-cv-00385-PCP Plaintiffs, 8

ORDER GRANTING DEFENDANT’S

9 v. MOTION FOR SUMMARY

JUDGMENT & DENYING

10 UNITED STATES OF AMERICA, PLAINTIFFS’ MOTION FOR

SUMMARY JUDGMENT

Defendant. 11 12 13 This is a quiet title action regarding the validity of a federal tax lien placed on a residential 14 property in Saratoga, California. Jeffrey T. Yu and plaintiff Olivia L. Yu transferred that property 15 into a Qualified Personal Residence Trust (QPRT) in 1996. Nominal title to the property, however, 16 was subsequently transferred back to the Yus on various occasions. After Jeffrey Yu incurred a 17 substantial tax debt, the federal government placed a lien on the residential property at a time 18 when nominal title to the property was held by the Yus rather than by the trust. The validity of the 19 lien depends upon whether the property was at that time owned by the Yus (in which case it is 20 valid) or by the trust (in which case it is invalid). 21 Now…