William Little v. United States

15 F.3d 1086 73 A.F.T.R.2d 94 -638 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. William LITTLE, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee. No. 93-55738. United States Court of Appeals, Ninth Circuit. Submitted Dec. 6, 1993. * Decided Dec. 21, 1993. Before: SNEED, NOONAN, and TROTT, Circuit Judges. 1 MEMORANDUM ** 2 William Little appeals the district court's dismissal for lack of subject matter jurisdiction of his action against the United States for wrongful levy under 26 U.S.C. Sec. 7426 . Little sued to recover two payments he made to the Internal Revenue Service ("IRS") towards tax liabilities assessed against his property. The IRS had filed liens against the property to collect the unpaid tax liabilities of one of the property's former owners. We have jurisdiction under 28 U.S.C. Sec. 1291 , and we affirm. 3 The district court dismissed Little's action for lack of subject matter jurisdiction because he failed to bring the action within…