1. Whether a quiet title action brought against the government pursuant to 28 U.S.C. § 2410(a) requires the taxpayer to retain a legal interest in the subject property, as the Sixth, Ninth, and Eleventh Circuits hold, or whether the attachment of a federal tax lien to the subject property is sufficient alone to abrogate the government's sovereign immunity under that provision, as the Third and Fifth Circuits hold.

2. Whether the government may lawfully invoke its sovereign immunity to a taxpayer's 28 U.S.C. § 2410(a) claim after luring the taxpayer into ceding his legal interest in the subject property and concluding an undisclosed side agreement with a third party to dispose of the property for a fraction of its actual worth.

3. Whether the government may selectively deplete a taxpayer's assets by voluntarily forfeiting the fair market value realized from the sale of his home and recouping the shortfall by levying on his remaining assets.

Whether a quiet title action requires taxpayer legal interest in property