Evans v. United States

MEMORANDUM OPINION

BATES, District Judge.

Plaintiff seeks damages against the United States pursuant to 26 U.S.C. § 7431(a)(1) based on alleged unlawful disclosures of confidential tax return information by the Internal Revenue Service (“IRS”) when it recorded a notice of federal tax lien against plaintiff in the public record. See Compl. ¶¶ 1-13. Defendant has filed a motion to dismiss for lack of subject matter jurisdiction or, in the alternative, for failure to state a claim upon which relief can be granted.

BACKGROUND

Plaintiff alleges that he is “the subject of ongoing purported collection…