Wee Luv Childcare, Inc. v. United States Ex Rel. Internal Revenue Service

ORDER

DAVID L. RUSSELL, Chief Judge.

Before the Court are Plaintiffs’ motion for summary judgment on their Complaint and Defendant’s objection and cross-motion for dismissal or summary judgment.

In support of their motion, Plaintiffs assert that this Court has jurisdiction under 26 U.S.C. § 7426(a)(1), inasmuch as a “levy” includes “seizure by any means,” 26 U.S.C. § 6331(b), and,the exercise of dominion and control over property; under 28 U.S.C. § 1346(a)(1) for wrongful collection of the proceeds of the sale of assets of Plaintiff Wee Luv Childcare, Inc. to recover internal revenue taxes; and…