Sally Conforte v. United States of America

NOONAN, Circuit Judge:

With tax liabilities of over $17 million, Sally Conforte has brought this action in an effort to get a $15 million credit against these liabilities, asserted by her to be the going concern value of her brothel, now levied upon and sold by the United States. Her effort to litigate her tax liabilities in this fashion fails. We dismiss those causes of action of which the district court had no jurisdiction. We affirm summary judgment against Conforte as to those causes of action over which the district court had jurisdiction.

BACKGROUND

Conforte was the owner with her husband…