Austin and Laurato, P.A. v. United States

Two law firms, Austin and Laurato, P.A. and Sisco-Law, P.A. (collectively, “the Firms”) appeal from the district court’s order dismissing their wrongful levy civil action against the United States for lack of subject matter jurisdiction. The district court concluded sua sponte that the Firms lacked Article III standing, and also agreed with the government that dismissal was warranted because the Firms failed to bring their wrongful levy action within the nine month limitations period prescribed by Congress in 26 U.S.C. § 6582(c). The district court further denied as futile the Firms’ request…