In the Estate of Norman L. Johnson, Deceased. Melvin M. Engel, of the Estate of Norman L. Johnson, Deceased v. United States

CAROLYN DINEEN KING, Circuit Judge:

Melvin M. Engel, the executor of the estate of Norman L. Johnson, appeals from the district court’s dismissal of his suit to quiet title to property clouded by federal tax liens. The district court dismissed the executor’s suit on the ground that the district court lacked subject matter jurisdiction over the dispute, given the United States’ failure to waive sovereign immunity in such cases. Finding the district court in error on this point, we reverse and remand.

I

The facts of this case are largely undisputed. On February 4, 1983, the United States Internal…