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Robinson v. United States
United States Court of Appeals for the Third Circuit
920 F.2d 1157 (1990)
- Written by Daniel Clark, JD
Facts
The Internal Revenue Service (IRS) determined that Albert Robinson (plaintiff) had underpaid his taxes. The IRS, however, never sent Robinson a notice of deficiency, which would have allowed him to contest the IRS’s determination in the United States Tax Court. The IRS assessed the deficiency and, as part of its effort to collect, filed a lien on Robinson’s home. Robinson then filed an action against the United States (defendant) under 28 U.S.C. § 2410(a) to quiet title in district court. For the purposes of the suit, Robinson conceded that the assessment was valid. The district court dismissed for lack of jurisdiction, and Robinson appealed.
Rule of Law
Issue
Holding and Reasoning (Weis, J.)
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