In Adam v. U.S., No. 8:05-cv-00987 (C.D. Cal. 12/28/11), the U.S. District Court for the Central District of California, in a case remanded by the Ninth Circuit, dismissed two siblings' suit for quiet title to property, holding that they only held bare legal title to the property as nominees for their parents under California law and, therefore, lacked standing under 28 USC §2410 (Judiciary and Judiciary Procedure) to challenge federal tax liens filed against their parents that attached to the property.