Petersen
Petersen v. Internal Revenue Service
Opinion
Trial Court Opinion
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA 10 CRAIG PETERSEN, Case No. 21-cv-01345-BAS-AGS
Plaintiff,
ORDER GRANTING DEFENDANTS
v. IRS AND UNGER’S MOTION TO DISMISS (ECF No. 10) INTERNAL REVENUE SERVICE, et al.,
Defendants. 16 Mr. Petersen, acting pro per, brings this action against the Internal Revenue Service (“IRS”), its revenue officer Joseph Unger, and Stefan Kasain claiming wrongful levy of taxes against the bank account of Crystal Castle Alliance, an organization of which Plaintiff alleges he is the “Director, President, Treasurer and Secretary.” (Compl. ¶¶ 3, 8.) According to the Complaint, this wrongful levy occurred as a result of Kasain’s tax debts. (Id. ¶ 6.) The IRS and Unger move pursuant to Rules 12(b)(1), 12(b)(5), and 12(b)(6) to dismiss the action against them. (ECF No. 10.) Plaintiff responds (ECF No. 14), and the Government replies (ECF No. 15). The Court finds this motion suitable for determination 26 …