Legal Opinion
Said Hassen v. Government of the Virgin Islan
Court of Appeals for the Third Circuit
Decided June 26, 2017No. 16-2209PublishedCited by 36 opinions
1Opinion of the Court
OPINION
(June 26, 2017)
Shwartz, Circuit Judge
Said and Karen Hassen (“the Hassens”) appeal the District Court’s order dismissing their claim against the Government of the United States Virgin Islands (“USVI”) and the Bureau of Internal Revenue (“BIR”) for imposing allegedly wrongful levies on their property in violation of 26 U.S.C. § 7433(a). To bring a claim under § 7433(a), a taxpayer must exhaust the administrative remedies set forth in § 7433(d). While such exhaustion is not a jurisdictional requirement, it is mandatory. Here, we need not decide whether the Hassens fulfilled this…
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