Living Care Alternatives of Utica, Inc. v. United States, Internal Revenue Service

OPINION AND ORDER

SARGUS, District Judge.

This case was initiated by Plaintiff (Living Care) filing a document entitled “Complaint for Redetermination of Notice of Intent to Levy and Appeal of Defendant’s Sustaining of Levy and Appeal of Liability.” Doc. 1, Comp., Title. Asserting this Court’s jurisdiction pursuant to 26 U.S.C. § 6330(d)(1)(B), Living Care says in effect that it is appealing “an adverse determination by the Internal Revenue Service ... at a due process hearing under Sec. 6320 of the Internal Revenue Code [IRC] ... as to the appropriateness of a filed Notice of Federal Tax Lien…