Allied/royal Parking L.P., a Limited Partnership Robert Silberman Bruce Silberman v. United States

BOOCHEVER, Circuit Judge:

In this case, we must determine whether 26 U.S.C. § 7433(a) confers a taxpayer with standing to sue the United States where the Internal Revenue Service places a wrongful levy on property that does not belong to the taxpayer, but where the taxpayer nonetheless suffers an injury from the failure to release the levy.

FACTS

Allied/Royal Parking L.P. (“Allied”) is a California limited partnership that provided parking management services in Los Angeles from 1990 through 1994. Bruce Silberman (“Bruce”), and Robert Silberman (“Robert”) were limited partners of Allied. During…