MRCA Information Services v. United States

MEMORANDUM OF DECISION RE REVIEW OF INTERNAL REVENUE SERVICE’S DETERMINATION

COVELLO, Chief Judge.

This is an action for injunctive relief and review of an administrative appeals determination made by the Internal Revenue Service, (“IRS”), wherein the plaintiff seeks to restrain the government from levying upon the plaintiffs assets to pay an outstanding tax liability for one year from the date of judgment. It is brought pursuant to 26 U.S.C. § 6330, 1 which provides a taxpayer with the right to a Collection Due Process hearing (“CDP”) before a levy may issue against any property. The plaintiff…