Legal Opinion

Sullivan v. United States

United States Court of Federal Claims

Decided October 21, 2016No. 15-1558TPublished

1Opinion of the Court

Tax Refund Claim; Subject Matter Jurisdiction; Failure to Pay Taxes or Submit Administrative Claim to IRS; Injunctive Relief.

OPINION AND ORDER ON DEFENDANT’S MOTION TO DISMISS

WHEELER, Judge.

Plaintiff James D. Sullivan filed a pro se complaint against the United States in this Court on December 21, 2015. Mr. Sullivan alleges that the Internal Revenue Service (“IRS”) wrongly assessed his 2006 taxes and unlawfully seized a payment from him under a federal tax lien to satisfy his tax liability for that year, The official record for Mr. Sullivan’s 2006 tax liability reflects an outstanding balance…

2Cases cited21 opinions

  1. Haines v. KernerSupreme Court of the United States · 1972
  2. United States v. MitchellSupreme Court of the United States · 1983
  3. Karen S. Reynolds v. Army and Air Force Exchange ServiceCourt of Appeals for the Federal Circuit · 1988
  4. Fisher v. United StatesCourt of Appeals for the Federal Circuit · 2005
  5. Flora v. United StatesSupreme Court of the United States · 1958

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