Teresa Tiernan v. United States

OPINION AND ORDER

LETTOW, Judge.

In this tax case, plaintiff, Teresa Tiernan, requests a refund of income taxes that were collected by levy against her assets, including her house, as well as damages for the allegedly wrongful imposition of liens and levies instituted against her. 1 Pending before the court is the government’s motion to dismiss for lack of subject matter jurisdiction pursuant to Rule 12(b)(1) of the Rules of the Court of Federal Claims (“RCFC”) or, alternatively, for failure to state a claim upon which relief can be granted pursuant to RCFC 12(b)(6).

BACKGROUND

Ms. Hernán did not…