Olsen v. United States

MEMORANDUM AND ORDER ON DEFENDANT’S MOTION TO AFFIRM AND DISMISS '

LINDSAY, District Judge.

I. Introduction

Invoking due process rights guaranteed under a section of the Restructuring and Reform Act of 1998, 26 U.S.C. § 6330, the plaintiff, Richard E. Olsen (“Olsen” or the “plaintiff’), seeks judicial review of a decision of an appeals officer of the Internal Revenue Service (“IRS”). The decision, which allowed a levy on ‘the plaintiffs property to secure the satisfaction of unpaid taxes, was made after the plaintiff requested and received a hearing to challenge the proposed enforcement action.…