Opinion

Pollinger v. Internal Revenue Service Oversight Board

  • 362 F. App'x 5
Court
Court of Appeals for the Eleventh Circuit
Filed
Jan 15, 2010
Status
Unpublished
Author
Carnes
On the bench
Birch, Carnes, Marcus, Per Curiam
Cited by
4 cases
Authority
More cited than 23.8%

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).

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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