Hughes v. Internal Revenue Service
Plaintiffs Ramon and Nazzari Hughes sued the Internal Revenue Service (IRS) and its agent Lawrence R. Engel, alleging a wrongful levy on their bank account, asserting that the seized funds were exempt Social Security Disability payments. Defendants, the United States of America and the IRS, moved to dismiss the actions for lack of jurisdiction and failure to state a claim. The court granted the motion to dismiss, ruling that claims under Internal Revenue Code sections 6334(a)(10), 6334(a)(11), and 6334(b)(3) were dismissed with prejudice, as the exemption for 'payable' amounts did not apply to funds already paid into a bank account. Claims related to due process and IRC sections 7432 and 7433 were dismissed without prejudice, allowing for repleading. Ultimately, the entire case was dismissed with prejudice for failure to prosecute after the plaintiffs failed to file amended complaints within the court's specified timeframe.