Rae v. United States (In Re Rae)

MEMORANDUM OF DECISION GRANTING DEFENDANT’S MOTION TO DISMISS ADVERSARY COMPLAINT

ALBERT S. DABROWSKI, Bankruptcy Judge.

I. INTRODUCTION

The matter before the Court is the Defendant United States’ Motion to Dismiss for Lack of Jurisdiction (hereafter, the “Motion to Dismiss”), ECF No. 9, wherein the United States of America Internal Revenue Service (hereafter, the “IRS”) seeks to dismiss the adversary complaint (hereafter, the “Complaint”), ECF No. 1, filed by Robert Rae, a/k/a Robert Lilly (hereafter, the “Plaintiff”) on the grounds that this court lacks subject matter jurisdiction over the…