United States Ninth Circuit

District Court's dismissal of an action alleging that the IRS wrongfully levied upon funds that did not belong to plaintiff is reversed where the nine-month limitations period set by 26 U.S.C. Section 6532(c) is not jurisdictional and may be equitably tolled. On remand, the court is directed to resolve whether plaintiff established grounds for equitable tolling.

Appellate Information

• Decided 01/30/2015
• Published 01/30/2015

Judges

• Watford

Court

• United States Ninth Circuit

Counsel