Jan Major Mengedoht, Individually, and as Executor of the Carl A. Mengedoht Estate and as Trustee of the H C J Holdings Trust - Carl A. Mengedoht - H C J Holdings Trust v. United States
1. May a federal court exercise subject matter jurisdiction in an action to "reduce to
judgment " an asserted estate tax lien case where exhibits in the court record establish that
a. the decedent had conveyed the property sought to be sold "in satisfaction " years
prior to his passing; and,
b. there is no evidence in the administrative record that the estate involved met the
federal estate tax filing threshold in effect for the year of decedent 's passing?
2. May a federal court exercise such subject matter jurisdiction in said action where the
administrative record establishes that
a. the purported "assessment " upon which the claimed "estate tax lien" was made by
an employee of the "Small Business/Seif-Employed " ("Examination ") Division; rather
than
b. by the delegate of the Secretary of Treasury duly-appointed as an assessment
officer pursuant to 26 C.F.R. § 301.6203-1 ?
May a federal court exercise subject matter jurisdiction in an action to reduce to judgment an asserted estate tax lien case