1. Whether “[r]espondent, by their own admissions, monetized Petitioner’s assets in the amount of $212,945 without jurisdiction and violated their own policies and procedures, Title 26 ยง 6212 and 6213 (a).”
2. Whether “[b]oth the United States Court of Federal Claims and the United States Court of Appeals incorrectly adjudicated the case as tax refund suit and not a jurisdictional suit.”
