Legal Opinion
Simon v. Doe
District Court, S.D. New York
Decided December 4, 2006No. 04 Civ. 6751(RJH)PublishedCited by 2 opinions
1Opinion of the Court
MEMORANDUM OPINION AND ORDER
HOLWELL, District Judge.
Pro se plaintiff Steven Simon filed suit pursuant to 26 U.S.C. § 6330(d)(1)(B), seeking review of an administrative decision of the Internal Revenue Service (“IRS”), which upheld a levy on Simon’s property for unpaid federal employment taxes, interest, and penalties. Pending before the Court is the IRS’s motion to dismiss for lack of subject matter jurisdiction, pursuant to Federal Rule of Civil Procedure 12(b)(1). For the reasons set forth below, the motion [9] is granted.
BACKGROUND
Steven Simon, a self-employed mortgage broker, incurred a…
2Cases cited7 opinions
- United States v. John & Patricia FormaCourt of Appeals for the Second Circuit · 1994
- American Radiator & Standard Sanitary Corp. v. United StatesUnited States Court of Claims · 1963
- United States v. Commercial National Bank of Peoria, as of the Estate of Joseph G. O'BrienCourt of Appeals for the Seventh Circuit · 1989
- Weisman v. CommissionerDistrict Court, E.D. New York · 2000
- Fox v. Board of Trustees of the State University of New YorkCourt of Appeals for the Second Circuit · 1994
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3Cited by2 opinions
- Rubery v. Buth-Na-Bodhaige, Inc.District Court, W.D. New York · 2007
- Special Touch Home Care Services, Inc. v. United StatesDistrict Court, E.D. New York · 2022