Ronald James, and Kay James v. United States

LOGAN, Circuit Judge.

Ronald and Kay James (plaintiffs) appeal summary judgment against them in their quiet title action against the United States under 28 U.S.C. § 2410. Although plaintiffs claimed procedural irregularities in the tax levy on Mr. James’ wages, the district court found that the case was, at heart, a challenge of the tax liability for which the levy was established and held that it had no jurisdiction to hear the matter. It then entered summary judgment in favor of the United States. 1

Mr. James did not file, income tax returns for the years 1981 and 1984. The federal Internal…