Luke Adam v. United States

MEMORANDUM

Plaintiffs-Appellants Luke and Chandra Marie Adam (the Adams) hold legal title to a piece of real property in Yorba Linda, California (the Property), upon which the Internal Revenue Service (IRS) placed liens to satisfy the tax obligations of the Adams’ parents, Dino and Trina Adam (the taxpayers). The IRS executed the liens under the theory that the Adams own the Property as the nominees of the taxpayers.

The Adams brought suit under 28 U.S.C. § 2410 to quiet title in the Property. The district court concluded that the Adams hold legal title to the Property as nominees of the taxpayers under California law, and dismissed the Adams’ complaint for lack of standing. On appeal, the Adams argue that the district court erred in concluding that they hold title to the Property as nominees of the taxpayers, and in further holding that they lack standing to challenge the procedural validity of the tax assessment giving rise to the liens on the Property. Because the parties are familiar with the factual and procedural history of this case, we repeat only those facts necessary to resolve the issues raised on appeal.

The district court accurately concluded that the Adams hold…