Jay R. Orme Julie Ann Orme v. United States of America, and Balyeat Law, P.C., as Trustee

TASHIMA, Circuit Judge:

The United States appeals the district court’s grant of summary judgment in favor of Jay R. Orme and Julie Ann Orme. We have jurisdiction pursuant to 28 U.S.C. § 1291, and we reverse.

The Ormes had transferred real property to Clyde M. Burgess and Janice K. Burgess pursuant to a land sales contract. During the term of the contract, the United States filed a federal tax lien on the property against the Burgesses. Thereafter, the Burgesses forfeited the land sales contract and title was returned to the Ormes. The Ormes sought to quiet title to the property. The district…