Donald E. Raulerson v. United States of America, Commissioner of Internal Revenue, Department of Justice

KRAVITCH, Circuit Judge:

In this action for declaratory judgment and injunctive relief, appellant sought a determination of the priority of claims against the same property by different federal agencies, and an order directing the IRS to enforce its lien. The district court granted summary judgment for the government. Concluding that the federal courts lack jurisdiction, we vacate the judgment and dismiss the appeal.

On July 9, 1981, the IRS made a 1.7 million dollar jeopardy assessment for 1980 taxes against Donald Raulerson. On July 13, the IRS issued a tax lien against Raulerson’s property…