holding that section 7432 does not “allow for actions regarding assessment of tax liability”
How later courts described this case
- holding that section 7432 does not “allow for actions regarding assessment of tax liability”
- “Pollinger’s argument that the government was required to produce a Form 23C to support a Form 4340 is … without merit.”
- insured’s counsel admitted insured knew material statement was false
Written by the judges who cited it.
The opinion
CARNES,
concurring in part and dissenting in part:
I concur in all of the Court’s decision, except the denial of sanctions. Notwithstanding the fact that the appellant is proceeding pro se, I would impose sanctions because his arguments are all utterly frivolous, the district court’s decision put him on notice of that fact, and he still appealed. United States v. Morse, 532 F.3d 1130, 1133 (11th Cir.2008); Webb v. Commissioner of Internal Revenue, 872 F.2d 380, 382 (11th Cir.1989); Stoecklin v. Commissioner of Internal Revenue, 865 F.2d 1221, 1226 (11th Cir.1989).