Zahra Spiritual Trust v. United States

EDITH H. JONES, Circuit Judge:

Dar Al-Hikmah N.V., Inc., Mudin, Inc., and Zahra Spiritual Trust brought suit against the United States under 28 U.S.C. § 2410 to quiet title to certain real property and to discharge federal tax liens upon the property. Following a bench trial, the district court dismissed appellants’ consolidated action and declared the liens valid. Although the district court evaluated the evidence thoroughly and conscientiously, we must vacate and remand for additional proceedings consistent with this opinion.

I

PROCEEDINGS

This dispute arises out of a tax jeopardy assessment…