Irwin Koff Darline Ruth Koff v. United States

Upon rehearing, we contemplate the extent to which 28 U.S.C. § 2410 waives the United States’ sovereign immunity from suit in tax cases. Our previous unpublished memorandum, 978 F.2d 715, filed October 23, 1992, is withdrawn.,

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Irwin and Darline Koff (“the Koffs”), acting pro se, brought suit pursuant to 28 U.S.C. § 2410(a) to quiet title to certain of their property on which the IRS had placed federal tax liens. The Koffs allege that the liens are proeedurally defective, hence invalid. The district court granted summary judgment in favor of the government. We affirm.

The Koffs predicate their…