Locke v. United States

MEMORANDUM OPINION AND ORDER

CHRISTINE O.C. MILLER, Judge.

This ease is before the court after briefing on defendant’s motion to dismiss pursuant to RCFC 12(b)(1) for lack of subject matter jurisdiction. Defendant challenges jurisdiction over a claim for damages based on a wrongful tax levy. Argument is deemed unnecessary.

BACKGROUND

As an initial matter, the court is compelled to point out that the pleading and brief filed by plaintiffs’ counsel were deficient in almost every respect. Some egregious errors include incorrect case citations; case names without any citations; statutes that have…