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

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?

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? PARTIES TO THE PROCEEDINGS Parties listed upon the notice of appeal filed in the Eighth Circuit Court of Appeals (Case No 19-1265) were UNITED STATES OF AMERICA and Jan M. Mengedoht, individually, and as Executor of the Charles A. Mengedoht Estate, and as Trustee of H C J Holdings Trust; the action filed in the United States District Court for the District of Nebraska included WASHINGTON COUNTY TREASURER, which was not party to the appeal filed in the Eighth Circuit, nor to this Petition.