United States Seventh Circuit

Court lacked subject matter jurisdiction over taxpayer's wrongful levy action against the IRS where taxpayer did not file suit within the nine-month period required for wrongful levy actions under 26 USC 6532(c)(1), and government did not waive sovereign immunity.

Appellate Information

• Argued 10/24/2000
• Decided 12/07/2000
• Published 12/07/2000

Judges

• MANION, Circuit Judge., Before FLAUM, Chief Judge, and MANION and EVANS, Circuit Judges.

Court

• United States Seventh Circuit

Counsel

• For Appellant:
  
• Gerald S. Walsh,Peter J. Walsh (argued), Wauwatosa, WI, for Plaintiff-Appellant.


• For Appellees:
  
• Randolph L. Hutter (argued), Kenneth L. Greene, Department of Justice, Tax Division, Appellate Section, Washington, DC, for Defendant-Appellee.