Trustees of the Puritan Church v. United States

The District Court dismissed the complaint which sought first the return of realty seized and sold on execution by the United States in satisfaction of certain tax liens, and second, damages 1 ***for the wrongful detention of the property.

The District Court held that the suit for recovery of the realty was an unconsented suit against the United States and hence the court was without jurisdiction. The court then went on to pass on the merits of the claim assuming, arguendo, that it had jurisdiction, and held that the sale of the realty in partial satisfaction of appellants’ transferee tax…