Harold Wapnick v. United States of America and U.S. Clearing Corp.

Harold Wapnick, pro se, appeals from Judge Amoris order dismissing his complaint for lack of subject matter jurisdiction and denying his motions for a default judgment and to vacate the “judgment” of the Internal Revenue Service (“IRS”). Wapnick claims that the IRS made an invalid jeopardy assessment against him upon his failure to pay income taxes for the years 1985, 1986, and 1987.

Challenges to jeopardy assessments by the IRS are governed by 26 U.S.C. § 7429. Section 7429 provides for judicial review by the district courts in general, § 7429(b)(2)(A), and by the United States Tax Court in…